Text

Insp Repts 50-272/98-06 & 50-311/98-06 on 980622-0801. Violations Noted.Major Areas Inspected:Licensee Operations, Maint,Engineering & Plant Support
	ML18106A834
Person / Time
Site:	Salem
Issue date:	08/21/1998
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML18106A832	List: IR 05000272/1998006; ML18106A831;
References
	50-272-98-06, 50-272-98-6, 50-311-98-06, 50-311-98-6, NUDOCS 9808260157
	Download: ML18106A834 (38)
	v • d • e

Docket Nos:

License Nos:

Report N Licensee:

Facility:

Location:

Dates:

Inspectors:

Approved by:

U. S. NUCLEAR REGULATORY COMMISSION 50-272, 50-311 DPR-70, DPR-75

REGION I

50-27 2/98-06, 50-311 /98-06 Public Service Electric and Gas Company Salem Nuclear Generating Station, Units 1 & 2 P.O. Box 236 Hancocks Bridge, New Jersey 08038 June 22, 1998 - August 1, 1998 S. A. Morris, Senior Resident Inspector F. J. Laughlin, Resident Inspector H. K. Nieh, Resident Inspector K. S. Kolaczyk, Reactor Engineer, NRC Region I J. D. Noggle, Senior Radiation Specialist, NRC Region I James C. Linville, Chief, Projects Branch 3 Division of Reactor Projects 9808260157 980821

~DR ADOCK 05000272 PDR

EXECUTIVE SUMMARY Salem Nuclear Generating Station NRC Inspection Report 50-272/98-06, 50-311 /98-06 This integrated inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a six-week period of resident inspection; in addition, it includes the results of announced inspections by region-based inspectors evaluating the_inservice inspection program and the radioactive waste management progra Operations Operations department performance was generally focused on safety-conscious plant operation, however, two instances of operator errors contributed to a reverse-power trip of a diesel generator output breaker and the overflovy of a liquid waste collection tan (Section 01.1)

PSE&G demonstrated good initiative in recent efforts to identify and minimize primary plant operational leakage source (Section 02.1 l Operators performed well during a Unit 2 controlled shutdown and cooldown for.a mid-cycle outage. An appropriate focus was maintained on shutdown cooling system status once Mode 5 conditions were achieved. (Section 01.2)

Equipment operability determinations were of good quality, and generally performed in accordance with procedural guidance. One exception was noted which involved the timeliness of a 125 volt DC system operability determination that was not consistent with the system's safety significance. Required audits of active operability determinations, were inconsistently performed, indicating a weakness in the implementation of program guidanc (Section 07.1)

PSE&G' s independent review groups, including the quality assurance department and the station operations review committee, continued to provide effective oversight of Salem operations. The corrective action review board sufficiently challenged the quality of completed corrective actions for previous issues and events. (Section 07. 2)

Maintenance The Salem plant staff completed observed maintenance and surveillance test activities effectively an in accordance with governing procedures. Maintenance support of operations was prompt and appropriate. The Unit 2 safety valve replacement effort was well planned and executed. (Section M1.1 l Plant risk was appropriately managed during the performance. of scheduled and emergent work activities. PSE&G self-identified weak performance with respect to recognition and implementation of compensatory measures associated with maintenance on service water ii

supply and return valves for two containment fan cooler units. Continued deficiencies associated with safety tagging program implementation were also evident. (Section M1.2)

PSE&G's immediate corrective actions for two unrelated emergency diesel generator fuel oil leaks were appropriate, however, corrective actions from the earlier leaks were narrowly focused. All technical specification action statement requirements were satisfied and the affected diesels were returned to service in a timely manner. Maintenance rule accounting for system unavailability time was proper. (Section M2.1)

PSE&G maintenance technicians failed to restore an auxiliary feed water (AFW) pump discharge pressure transmitter to an operable condition following an instrument calibration, resulting in the undetected inoperability of the 22 AFW pump for eigl")teen days. (Section M4.1)

PSE&G personnel appropriately monitored containment fan cooler units (CFCUs) in accordance with maintenance rule requirements. Weaknesses in system functional failure identification and classification were noted for the CFCU (Section M8.1)

Engineering Timely and appropriate engineering support of operations and maintenance was indicated by active participation in daily station interface meetings, as well as effective development of minor design changes and completion of several safety evaluations. (Section E1.1)

PSE&G implemented and maintained a satisfactory inservice inspection program at Sale The bases for selected ASME code relief requests were valid and accurate. Non-destructive examination personnel were properly trained in accordance with industry standards. (Section E2.1)

Plant Support Salem solid radioactive wastes were effectively sampled, packaged, and dewatered in accordance with requirements, however, the need to update the waste characterization and packaging program to include the filtrate wastes from the tubular ultra-filtration system prior to waste shipment remains. (Section R1.1)

PSE&G effectively limited the amount of stored contaminated equipment and radioactive wastes. (Section R1.2)

Salem radioactive waste processing and radioactive material shipping procedures were of good quality and effectively implemented regulatory requirements. (Section R3.1)

iii

TABLE OF CONTENTS EXECUTIVE SUMMARY.............................................. ii TABLE OF CONTENTS.............................................. iv I. Operations

02

08

...................................................... 1 Conduct of Operations..................................... 1 0 General Comments................................... 1 01.2 Salem Unit 2 Shutdown for Mid-Cycle Outage................ 2 Operational Status of Facilities and Equipment.................... 3 0 Reactor Coolant System Operational Leakage Monitoring........ 3 Quality Assurance in Operations.............................. 4 07.1 Operability Determination Review........................ 4 07.2 Independent Review and Oversight of Salem Operations........ 5 Miscellaneous Operations Issue.................... :.......... 6 0 (Closed) VIO 50-272,311/97-012.:.02............ ;......... 6

. 08.2 (Closed) LER 50-311/97-004-00......................... 7 08.3 (Closed) LER 50-311/97-012-00......................... 7 08.4 (Closed) LER 50-311/97-013.:.oo......................... 8 08.5 (Closed) LER 50-272/98-006-00......................... 9 08.6 (Closed) VIO 50-311/97-021-01......................... 9 II. Maintenance.......................................... c..*****.. 10 M 1 Conduct of Maintenance................................... 1 0 M1.1 General Comments.................................. 10 M1.2 Implementation of the Work Management Process............ 11 M2 Maintenance and Material Condition of Facilities and Equipment....... 13 M2.1 Emergency Diesel Generator Fuel Oil Leaks................. 13 M4 Maintenance Staff Knowledge and Performance.................. 14 M4.1 Inoperable Motor-Driven Auxiliary Feed Water Pump.......... 14 M8 Miscellaneous Maintenance Issues............................ 17 MS.1 Verification of 10 CFR 50.65 ("Maintenance Rule") Requirements for Unit 1 Containment Fan Cooler Units..................... 17 Ill. Engineering.................................................... 18 E1 Conduct of Engineering.................................... 18 E1.1 Support to Operations and Maintenance................... 18 E2 Engineering Support of Facilities and Equipment.................. 19.

E lnservice Inspection................................. 19 E7 Quality Assurance in Engineering Activities...................... 21 E7.1 Quality Assurance Review of Design Change Packages........ 21 ES Miscellaneous Engineering Issues............................. 21 E (Closed) LER 50-272/96-028-00........................ 21 E (Closed) LER 50-272/98-001-00........................ 22 E (Closed) VIO 50-272,311/98-001-10..................... 23 IV. Plant Support.................................................. 24

iv

R1 Radiological Protection and Chemistry (RP&Cl Controls............. 24 R1.1 Salem Solid Radioactive Waste Processing................. 24 R1.2 Solid Radioactive Waste Storage........................ 25 R3 RP&C Procedures and Documentation......................... 26 R Radioactive Material Shipment Procedures................. 26 R5 Staff Training and Qualification in RP&C........................ 27 R Radioactive Material Shipment Training................... 27 R7 Quality Assurance in RP&C Activities.......................... 27 R7.1 Radioactive Material Shipping Audit....................... 27 RS Miscellaneous RP&C Issues................................. 28 R (Closed) URI 50-272,311 /97-012-01..................... 28 P2 Status of EP Facilities, Equipment, and Resources................. 28 P Temporary Loss of Alert Notification System Sirens........... 28 SS Miscellaneous Security and Safeguards Issues................... 29 S (Closed) VIO 50-272,311/E97-422-01013................. 29 V. Management Meetings............................................ 30 X 1 Exit Meeting Summary.................................... 30 X2 Management Meeting Summary.............................. 30

v

Report Details Summary of Plant Status Unit 1 began the period at 100% power and remained at or near full power for the duration -

of the inspection perio Unit 2 began the period.at 100% power, and remained at full power until July 24, 1998, when operators commenced a controlled shutdown for a mid-cycle outage to replace a leaking pressurizer safety valve. The unit entered Mode 5 (Cold Shutdown) on July 26, 1998, and remained in this condition until the end of the report perio I. Operations

Conduct of Operations 01.1 General Comments Inspection Scope (71707)

The inspectors conducted frequent reviews of ongoing plant operations, and compared operations department performance with the management expectations defined in procedure SH.OP'-DD.ZZ-0004, JJOperations Standards." Observations and Findings In general, the conduct of operations was professional and safety-consciou Adherence to operations department performance expectations, including those for log taking, communications, technical specification (TS) action statement tracking, and use of procedures was good. When required, 10 CFR 50. 72 non-emergency event reports were made to the NRC operations center in a timely and accurate manner. The inspectors verified that pre-staged procedures for in-field use ( remote emergency diesel generator operating procedures) were properly controlled and of the current revisio Two self-revealing human performance errors were noted. In the first case, on June 18, 1998, an equipment operator caused a reverse-power trip of the 2C emergency diesel generator (EOG) output breaker when he did not raise load on the generator in a timely manner. A similar event occurred on January 22, 1998, when an operator's failure to raise load promptly resulted in an output breaker trip for the 2A

EOG. Corrective actions from the January event, which included a revision to the EOG operating procedures to caution operators to raise load promptly following breaker closure, had not been implemented before the June 18 event. No safety consequences resulted in either cas A second human performance issue also surfaced on June 18, 1998, when operators discovered that the No. 1 2 chemical and volume control system (CVCS)

monitoring tank had overflowed. _This tank receives waste water from the boric

acid evaporator and various other sources. This occurrence did not result in any adverse radiological or other consequences, and was attributed to a poor operations department turnover and inefficient oversight of the status of the radioactive waste syste Conclusions Operations department performance was generally focused on safety-conscious plant operation, however, two instances of operator errors contributed to a reverse-power trip of a diesel generator output breaker and the overflow of a liquid waste collection tan.2 Salem Unit 2 Shutdown for Mid-Cycle Outage Inspection Scope (71707)

The inspectors performed frequent observations of control room operators during the conduct of a Unit 2 plant shutdown to Mode 5 (Cold Shutdown). Established controls over shutdown cooling system reliability were reviewed. Selected portions of normally inaccessible safety systems were visually inspected during the outag Observations and Findings

On July 24, 1998, control room operators commenced a controlled shutdown of Salem Unit 2 for a mid-cycle outage, primarily to replace a leaking pressurizer code safety valve with valve of a different design. These valves were replaced once previously with an identical design during a February 1998 mid-cycle outage, but exhibited similar seat leakage shortly after the plant resumed power operatio Station management added a third licensed reactor operator to the operating shift complement in support of the shutdown and cooldown activities. The inspectors witnessed good performance by plant operators, including excellent use of procedures. Alarm response was also prompt and appropriate. Operators demonstrated a good understanding of expected plant responses to the changing plant conditions and evolutions. Control room communications were clear and concise, and in the three-way format prescribed by department performance standards. The unit entered Mode 5 on July 26, 199 Once in Cold Shutdown conditions, the inspectors verified that operators were cognizant of the current status of the shutdown cooling system (residual heat removal - RHR) alignment. Additionally, the inspectors confirmed that appropriate controls were in place to protect the necessary RHR support systems, including station service water, component cooling water, and electrical power source Operators maintained an appropriate focus on core exit thermocouple readings, as well as RHR system flows and heat exchanger inlet temperatures. Technical specification requirements for the changing operational modes were properly tracked and implemented.

- - - - - - -

The inspectors conducted several tours of the Unit 2 containment building while the unit was in Mode 5, and observed the physical condition of several normally inaccessible safety system components. No deficiencies or concerns were identifie Conclusions Operators performed well during a Unit 2 controlled shutdown and cooldown for a mid-cycle outage. An appropriate focus was maint.ained on shutdown cooling system status once Mode 5 conditions were achieve Operational Status of Facilities and Equipment 0 Reactor Coolant System Operational Leakage Monitoring Inspection Scope (71707,37551)

The inspectors reviewed PSE&G's actions taken in response to indications of continued leakage from the Unit 2 reactor coolant syste Observations and Findings The Salem plant staff exhibited an appropriate level of concern for the continued leakage from the Unit 2 primary systems other than just the "identified" leakage from a pressurizer safety valve. During the report period several actions were implemer)ted to address the leakage issue. For example, maintenance was planned, scheduled and implemented to replac.. e the positive displacement charging pump seals and packing in an effort to minimize unidentified leakage from the chemical and volume control system. This effort had some limited effect on reducing unidentified leakage. Additionally, operators walked down safety injection system piping in the auxiliary building and discovered some primary system leakage past boron injection tank sample flask isolation valves. Once this source was isolated, unidentified leakage was further reduce During the leak identification and reduction effort, plant staff members discovered a statement in section 6.3 of the Salem UFSAR which indicated that all manual valves in the emergency cors:i cooling system flow paths were "backseated". Operators determined that the Tagging Request and Inquiry System (TRIS), which indicates actual and required status of most Salem components, did not include this backseat requirement *in the database. Upon discovery of this discrepancy, operators revised the TRIS system to account for the UFSAR requirement and backseated all of the affected man1Jal valves. However, little to no improvement in unidentified leakage reduction resulted from this activity. This failure to maintain the Salem facility in accordance with the design assumptions stated in the UFSAR constitutes a violation of minor significance and is not subject to formal enforcement actio Near the end of the report period, on July 24, 1998, operators commenced a controlled Unit 2 plant shutdown to replace the pressurizer code safety valves with

a different design to minimize identified leakage into the pressurizer relief tank (See section 01.2). Conclusions PSE&G demonstrated good initiative in their recent efforts to identify and minimize primary plant operational leakage source Quality Assurance in Operations 07.1 Operability Determination Review Inspection Scope (71707, 40500)

The inspectors reviewed the Salem operations department process for assessing and documenting the operability of plant structures, systems, and component Selected operability determinations were evaluated with the guidance specified in procedure SC.OP-AP.ZZ-0006, Operability Determination." The inspectors used NRC Generic Letter (GL) 91-18, "Information to Licensees Regarding Two NRG Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," as a referenc Observations and Findings Procedure SC.OP-AP.ZZ-0006 provided guidance consiste.nt with that specified in GL 91-18. At the time of the inspection, there were six open operability determinations (OD) at Salem. The inspectors reviewed the following OD's in detail:

98-011:

98-009:

98-007:

23 auxiliary feed water pump room cooler dampers 18 125 volt DC (VDC) ground Diesel generator starting air motor lubrication With one exception, the operations staff completed the selected ODs according to the guidance specified in SC.OP-AP.ZZ-0006 and GL 91-18. Specifically, OD 98-009 was initiated on May 29, 1998, nearly two weeks after a degraded condition was identified on the 18 125 VDC distribution system. During this two week period, PSE&G believed that they had sufficient basis for maintaining the battery system operable, but the inspectors concluded that the timeliness of formally documenting their basis in OD 98-009 was not consistent with the safety significance of the affected system. Nevertheless, the compensatory actions and engineering followup assessments for the degraded conditions were adequat PSE&G personnel corrected the conditions associated with ODs 98-007 and 98-009, and closed both ODs prior to the end of the inspection period. The inspectors also noted that most of the past ODs did not remain active for extended periods of time. Lastly, the inspectors reviewed the periodic audits of all open ODs and noted that these audits were not completed on a consistent basis. As expected by the noted operations department procedure, section 5.5 of this procedure states that these audits will normally be performed on a monthly basi *

5 Conclusions Equipment operability determinations were of good quality, and generally performed in accordance with procedural guidance. One exception was noted which involved the timeliness of a 125 volt DC system operability determination that was not consistent with the system's safety significance. Required audits of active operability determinations were inconsistently performed indicating a weakness in the implementation of program guidanc.2 Independent Review and Oversight of Salem Operations Inspection Scope (71707, 40500)

The inspectors reviewed the bi-monthly Quality Assurance (QA) department' audit report and discussed various findings with members of the QA staff. Additionally, the inspectors attended station operations review committee (SORC) and corrective action review board (CARB) meetings to evaluate their focus on safety and effectiveness in implementing programmatic requirements. Minutes of meetings not attended were also reviewe Observations and Findings Based on an integrated review of previous and current self-revealing issues and independent findings, the QA department established several categories of station

"focus areas." Focus areas were intended to indicate a potential area of weak performance for which station management should apply additional oversigh Examples of recent QA focus areas included technical specification implementation, corrective action program usage, licensed operator training, and equipment status control tracking. The inspectors noted that QA assessments had sound bases, and that feedback to line management was sufficiently critical and timely. Though QA concluded that overall operation of the plants was conducted safely, equipment safety tagging and human performance remained the areas of greatest concern. QA managernent appropriately adjusted inspection resources to provide added oversight in the noted focus areas, while maintaining routine inspections of other area The inspectors attended two SORC meetings during the report period. A legitimate quorum was represented at both meetings as required by the PSE&G QA progra SORC members were prepared to discuss the topics on the meeting agenda, and were sufficiently critical and safety-focused while evaluating the issues presente Meeting minutes accurately reflected SORC discussions and decision The inspectors also attended two CARB meetings, in which four individual presentations were made by various PSE&G staff members. In every case, the CARS members rejected the corrective action effectiveness reviews presented, indicating that the board maintained high standards for what constituted acceptable corrective actions for identified conditions adverse to quality.

Conclusions PSE&G's independent review groups, including the quality assurance department and the station operations review committee, continued to provide effective oversight of Salem operations. The corrective action review board sufficiently challenged the quality of completed corrective actions for previous issues and event Miscellaneous Operations Issue 0 (Closed) VIO 50-272,311 /97-012-02:1nadequate Corrective Actions for Configuration Control Deficiencies and a Degraded Auxiliary Feed Water Pipe Inspection Scope (92702)

The inspectors conducted an on-site review of the root cause(s) and verified selected corrective actions implemented for the subject violation. PSE&G's violation response letters dated July 30, 1997 and September 30, 1997 were reviewed during this assessmen Observations and Findings Two examples of 1 0 CFR 50 Appendix B vioiations were included In the subject citation. In the* first case, PSE&G concurred with the NRC's determination that operators did not promptly identify and correct a significant condition adverse to quality involvi_ng safety-related equipment configuration control. Specifically, PSE&G concluded that, as a result of personnel errors, insufficient attention was applied to updating and reviewing the electronic Tagging Request and Inquiry System database. Corrective actions for this issue focused on re-emphasizing management expectations associated with configuration control and revising related procedure guidance. The inspectors verified that these actions were complete The second example involved a discovery that maintenance technicians had failed to complete all of the ultrasonic examinations specified in a work order for suspected auxiliary feed water piping degradation, which resulted in a failure to promptly identify and correct conditions adverse to qualit PSE&G again concurred with the NRC's findings, and attributed the cause of the occurrence to personnel error. Corrective measures included completing the missed ultrasonic examinations, applying the internal disciplinary process to the responsible individuals, and communicating the lessons learned from this event to maintenance, planning and engineering support personne Conclusions PSE&G implemented reasonable actions to correct two instances of personnel failures to identify and correct conditions adverse to quality.

08.2 (Closed) LER 50-311 /97-004-00: Failure to Comply with Technical Specification Action Statement, Diesel Generator Start, and Inadequate Surveillance Testing Inspection Scope (92700)

The inspectors reviewed the corrective actions and root cause analyses for the three issues described in the subject Licensee Event Report {LER). Observations and Findings Failure to Comply with Technical Specification Action Statement (TSAS)

This issue described in detail in inspection report 50-272,311 /97-07 as a violation, and was subsequently closed in report 98-03. No new issues were revealed in this LE.

Inadequate Surveillance Testing

This issue was also described in NRC Inspection Report 50-272,311 /97-07as a non-cited violation. Again, no new issues were revealed in this LE Unplanned Start of the 2A Emergency Diesel Generator (EOG)

During a post-maintenance test of a safeguards equipment cabinet (SEC), the 2A EOG started unexpectedly. PSE&G determined a EOG start signal was generated from the 2A SEC. PSE&G replaced the SEC that generated the signal with a spare unit. The SEC manufacturer tested and evaluated the original SEC and did not identify any equipment problems. PSE&G was unable to determine the exact cause of the automatic start signal, and attributed the most likely cause to human error during the SEC testing. PSE&G planned to revise the subject LER to remove the reference to an LER supplement documenting the results of the manufacturer's analysi Conclusions PSE&G response to and corrective actions for an unexpected engineered safety feature actuation of the 2A emergency diesel were reasonabl.3 (Closed) LER 50-311 /97-012-00: Entry into Technical Specification 3.0.3 Due to lnoperability of Two Overtemperature-Differential Temperature (OTDT) Channels Inspection Scope (92700)

The inspectors reviewed the nature, the corrective actions, and the root cause evaluation associated with the event described in the subject Licensee Event Report (LER).

8 Observations and Findings On September 7, 1997, a Unit 2 control operator noted that the reactor coolant loop (RCL) 24 actual differential temperature indicator failed to meet its channel check requirement, rendering the associated OTDT and overpower-differential temperature (OPDT) channels inoperable. At the time of the event, the RCL 23 OTDT protection circuit was inoperable due to ongoing maintenance activities associated with the RCL 23 pressurizer level instrumentation, however, the associated OTDT bistable was tripped as required by technical specifications (TS).

Since less than the minimum three of four OTDT protection channels Were operable, control room operators entered TS 3.0.3, which requires initiation of plant shutdown be commenced within one hour. PSE&G personnel secured the maintenance activities on the RCL 23 protection circuit, restored the RCL 23 protection circuit to an operable status, and exited TS 3.0.3 within the allowed time*

perio *

PSE&G personnel determined that the RCL 24 differential temperature channel check failure resulted from scaling the RCL 24 instrumentation using thermal performance data from the previous fuel cycle. Previous cycle data is normally used after plant startups from refueling outages since it is the best approximation of thermal performance until more precise data can be obtained at full power. In*

addition, conservatively set power range nuclear instruments contributed to the failed channel check..

Corrective actions included a calibration check of the RCL 24 differential temperature instrument, and full power thermal performance data was collected during the power ascension in order to properly scale the RCL 24 full power differential temperature. The inspectors concurred with PSE&G's assessment that this event had no safety consequence, and that safety implications were minimal since the RCL 23 OTDT was already in a safe condition (i.e., already tripped) and

the remaining two OTDT channels (RCL,21 and 22) were operabl Conclusions PSE&G operations personnel appropriately entered Technical Specification 3.0.3 in response to two inoperable overtemperature-differential temperature channel Corrective actions were appropriate and promptly implemente.4 (Closed) LER 50-311 /97-013-00: Unplanned Entry into Technical. Specification 3.0.3 Due to Two Inoperable Pressurizer Level Channels Inspection Scope (92700)

The inspectors reviewed the nature, the corrective actions, and root cause evaluation associated with the event described in the subject Licensee Event Report (LER).

9 Observations and Findings This event, which involved a valve manipulation error while troubleshooting a pressurizer level (Ip) transmitter problem, was initally described in NRC inspection report 50-272,311 /97.15.. Subsequent PSE&G investigation revealed that the noted valve (2PS9) was incorrectly labeled as the channel 3 transmitter isolation valve on the controlled drawing used by the maintenance personnel. PSE&G personnel determined that the Unit 2 channel 1 and 3 transmitter isolation valves were incorrectly swapped on the reactor coolant system drawings and in the maintenance management information system (MMIS) database. PSE&G attributed the cause to human error, in that personnel involved with drawing revisions may have incorrectly assumed that the Unit 2 channel configuration was identical to that of Unit 1. The inspectors verified completion of selected corrective actions that included correcting the affected. drawings, procedures, and the MMIS database. The safety implications of this event were minimal due to the prompt operator response and restoration of channel 1. Failure to ensure the adequacy of plant drawing revisions is a violation of document control requirements of 10 CFR 50, Appendix 8, Criterion VI. This non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Polic (N CV 50-311198-06-01 ) Conclusions Inadequate review of plant drawing revisions resulted in the incorrect labeling of two Unit 2 pressurizer level transmitter isolatio.n valves, causing maintenance personnel to inadvertently isolate an operable channel. Control room operators responded promptly and appropriately following the discovery. PSE&G's actions to correct the drawing errors were adequat.5 (Closed) LER 50-272/98-006-00: Engineered Safety Feature Actuation of the 11 and 12 Auxiliary Feed Water Pumps The circumstances described in this Licensee Event Report (LER) were previously documented in NRC Inspection Report 50-272&311/98-01 section 01.2 and dispositioned as a Non-Cited Violation of Technical Specification 6.8.1, for a failure to implement required procedures. The LER description of the event, including its root causes and corrective actions, was consistent with that described in the noted report. No new issues or concerns were revealed in this LE.6 (Closed) VIO 50-311197-021-01: Failure to Comply With Procedures For Equipment Status Control Inspection Scope (92702)

The inspectors reviewed PSE&G's April 3, 1998 violation response letter and verified selected corrective actions for the issues involve **

10 Observations and Findings This violation cited two examples of failures to comply with PSE&G procedures for equipment status control. In the response, PSE&G concurred with the NRC's findings and, in both cases, attributed the causes to personnel error exacerbated by inadequate communications and procedure weaknesses. Corrective measures included individual disciplinary actions, procedure revisions, and "lessons learned" discussions with operator In the March 5, 1998 letter which forwarded the 50-272&311 /97-21 inspection report, NRC management expressed a concern with the apparent repetitive nature of equipment status control issues at the Salem station, citing the events in the above noted violation as well as other earlier occurrences (see section 08.1 of this report).

A common aspect of all of these issues involved a failure to maintain the electronic Tagging Request and Inquiry System (TRIS) database accurate, and to apply tags to affected equipment to indicate the position (or condition) as off-normal. The inspectors noted that the corrective actions instituted following the discovery of the later occurrences were essentially the same as those for the earlier occurrences, suggesting that these measures may not be sufficient to prevent or minimize the potential for recurrence. However, though subsequent additional issues involving equipment status control have been identified (see section 02.1 and M4.1 of this report), only one of the later events were directly associated with failures to maintain the TRIS database accurate. Additionally, the inspectors determined that the one excepted circumstance was the result of uniquely different cause Conclusions

..

PSE&G implemented reasonable.corrective actions for repeat equipment configuration control issues resulting from failures to maintain an electronic system status databas II. Maintenance M 1 Conduct of Maintenance M1.1 General Comments (62707, 61726) Inspection Scope The inspectors observed numerous work activities and technical specification *

surveillance tests, including all or portions of the following activities:

Unit 1

W /0 990221 02 1 C2 1 25 volt DC battery charger *surveillance test

S1.OP-PT.SJ-0001 1SJ12 and 1SJ13 leakage test

S1.OP-ST.AF-0003 13 a,uxiliary feed pump inservice test

Unit 2

W/O 980521129 2A emergency diesel starting air motor modification

W/O 930527008 23 steam generator feed flow transmitter calibration

W/O 980407197 Pressurizer safety valve replacement (DCP 2EC-3650)

S2.0P-ST.CVC-0003 21 charging pump inservice test

S2.0P-ST.CS-0002 22 containment spray pump inservice test

S2.0P-ST.MS-0003 Main steam isolation valve stroke time testing

S2.0P-ST.AF-0007 23 auxiliary feed water pump inservice test Observations and Findings The inspectors observed that maintenance technicians performed observed work activities effectively and within the requirements of the station maintenance procedures. Additionally, the plant staff completed surveillance test activities safely, and effectively demonstrated the operability of the associated systems.

. With regard to the implementation of the Unit 2 pressurizer safety valve replacement design change package, the inspectors noted excellent oversight of the various work activities by all supporting station departments. Three new-design safety valves were installed without incident or delay, evidence that *pre-job planning and worker training was effective. Radiation exposure was effectively controlled at the job site. All needed tools and parts were staged at the work locatio The inspectors noted other examples of generally good maintenance support of safe plant operations, including resolution of emergent work activities. Such activities included replacement of a 23 reactor coolant pump bearing oil sump level switch, response to a failed service water bay sump pump, and repairs to leaking pressurizer level instrument valves. All of these activities promptly corrected abnormal indications or controls in the Salem control roo Conclusions The Salem staff completed observed maintenance and surveillance test activities effectively and in accordance with governing procedures. Maintenance support of operations was generally prompt and appropriate. The Unit 2 safety valve replacement effort was well planned and execute M1.2 Implementation of the Work Management Process Inspection Scope (71707, 62707)

The inspectors followed up on several PSE&G-identified or self-revealing issues associated with the implementation of the Salem work management proces * Observations and Findings The inspectors noted that plant risk was effectively managed during the performance of scheduled and emergent work activities. Unless a significant component degradation or failure was detected placing the station in an unplanned technical specification (TS) shutdown action statement, repairs for identified system or equipment degradation was deferred to appropriate pre-established work weeks to minimize risk. The inspectors observed several cases in which scheduled work activities were appropriately deferred in order to resolve emergent issues. For example, planned work on the 15 station service water (SSW) was delayed to accommodate an unexpected failure of the 12 SSW traveling screen, even though having both subsystems inoperable would not have placed the unit in a condition prohibited by TS or operating procedures. Risk was also minimized during the Unit 2 mid-cycle outage via effective implementation of an outage safety plan (Se section 01.2).

PSE&G self-identified several deficiencies associated with on-line work planning, *

scheduling, and execution. Most deficiencies were relatively minor, involving administrative issues. There were several significant concerns as well. For example, on June 26, 1998, an on-shift operations department shift technical advisor discovered that there was no TS 3.6.3 action statement entry for an ongoing planned maintenance activity on the No. 22 containment fan* cooler unit (CFCU) service water inlet valve (22SW58), which is an individual containment

isolation valve. No TS violation resulted from the failure to track the action statement entry, since required compensatory measures were in place as a result of valve isolations necessary to support the work. However, the inspectors viewed the fact that there were no consequences as fortuitous, since the several weeks of work planning leading up to the actual execution of the planned maintenance failed to identify the need to address TS 3.6.3 requirements ahead of tim A second example of deficient work planning and oversight resulted in a one-hour 10 CFR 50.72 non-emergency event report on July 15, 1998. In this case, operators isolated the 13 CFCU to support work on the 22SW57 service water outlet valve. However, the established isolation boundaries temporarily removed the overpressure protection for the affected service water piping, which was installed in response to the concerns raised in NRC Generic Letter 96-06,

"Assurance of Equipment Operability and Containment Integrity During Design-Basis Accident Conditions." Upon recognition of this issue, workers drained the isolated portion of service water piping to eliminate the potential for post-accident overpressurization and ruptur The inspectors also noted that there were three safety tagging program implementation errors during the report period. The issues included a failure of operators to apply a blocking tag to the proper component, a failure of maintenance personnel to sign on to a tagout prior to conducting work, and a failure of a maintenance supervisor to verify that appropriate tagging boundaries were established prior to authorizing technicians to begin work. All three concerns were self-identified and corrected, and had no consequence on equipment or personn13I

safety. However, the inspectors concluded that collectively these issues indicated a lack of sensitivity to the requirements of NC.NA-AP.ZZ-0015, Safety Tagging Program," and that the potential to impact equipment or personnel safety adversely was real. PSE&G management expressed similar concerns as each of these circumstances were discovered. Since the cause of these issues was attributed to individual human errors, corrective actions were focused on implementing the station disciplinary policy for the responsible individual Other tagging deficiencies have been identified and documented in recent NRC inspection reports, including report 50-272,311 /98-03, in which a Non-Cited Violation was described involving the self-identified discovery of an improper release of a tagging boundary while maintenance activities were still being conducte Because these latest examples were also licensee-identified and corrected, and had no safety consequence, they are also collectively being treated as Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy. {NCV 50-272,311/98-02)

. Conclusions Plant risk was appropriately managed during the performance of scheduled and emergent work activities. PSE&G self-identified weak performance with respect to recognition and implementation of compensatory measures associated with maintenance on service water supply and return valves for two containment fan cooler units. Additional deficiencies associated with safety tagging program implementation were also identified and corrected by PSE& M2 Maintenance and Material Condition of Facilities and Equipment M Emergency Diesel Generator Fuel Oil Leaks Inspection Scope (62707)

The inspectors reviewed two events involving emergency diesel generator (EOG)

fuel oil leaks through personnel interviews and documentation revie Observations and Findings On April 12, 1998, operators started the 2A EOG for a monthly technical specification (TS) required surveillance test. During that test, operators discovered a fuel oil leak on the 9-Right fuel pump. Maintenance technicians discovered that two of the four fuel pump mounting bolts were loose, while the other two bolts were sheared off. PSE&G attributed the apparent ca\\jse of this issue to the application of insufficient mounting bolt torque during earlier maintenance, gradually loosening these bolts by vibration. After this issue was identified, all Unit 1 and 2 engines were thoroughly inspected for extent of condition; three additional loose bolts were found on the 18 EDG. Thes~ bolts were torqued to t.he proper valu PSE&G also revised the 18-month EOG inspection procedure to add a verification of proper mounting bolt torque valt,Je *

Later, during a July 7, 1998 surveillance run of the 1 B EDG, another fuel oil leak was discovered, this time on the 9-Left cylinder. Unlike the April 1 998 issue,

.further investigation revealed that two nearby fuel supply header bolts were loose resulting in a fuel oil leak at the gasket between the fuel supply header and the fuel pum Technicians discovered similar loose bolts on other 1 B EDG cylinders, as well as o*n the cylinders of other Unit 1 and 2 EDGs. All loose bolts were torqued to the proper value. Additionally, the fuel pump mounting bolts on the 1 B EDG were once again checked with no deficiencies noted. PSE&G's evaluation of this more recent event was not yet complete at the end of the inspection period, however, the inspectors concluded that corrective actions stemming from the April issues were narrowly focused on a check of the fuel pump mounting bolts, with no consideration for other potentially affected system fastener In both cases, control room operators appropriately started and ran the 1 A and 1 C EDG's during the time the 1 B EDG was inoperable for the noted corrective maintenance, as required by TS 3.8.1.8. The inspectors verified that the 1 B EDG unavailability time needed to conduct the necessary repairs was properly recorded in accordance with the Salem 10 CFR 50.65 maintenance rule progra Conclusions PSE&G's immediate corrective actions for two unrelated emergency Eliesel generator fuel oil leaks were appropriate, however, corrective actions from the earlier leaks were narrowly focused. All technical specification action statement requirements were satisfied and the affected diesels were returned to service in a timely manne Maintenance rule accounting for system unavailability time was prope *

M4 Maintenance Staff Knowledge and Performance M Inoperable Motor-Driven Auxiliary Feed Water Pump Inspection Scope (62707, 71707) The inspectors reviewed the circumstances which led up to the self-revealing discovery that the 22 auxiliary feed water (AFW) pump was inoperable for greater than the technical specification (TS) allowed outage tim Observations and Findings While low in power during a controlled Unit 2 shutdown on July 25, 1998, operators attempted to place the two 50% capacity motor-driven AFW pumps in service prior to removing the main steam generator feed pumps from operatio Both AFW pumps started normally, however the 22 AFW pump discharge valves (21AF21 and 22AF21 ), which open to provide flow to the 21 and 22 steam generators, failed to open as expected. These valves are designed to shut automatically when a transmitter on the pump discharge piping senses a low pressure condition in order to protect the pump from "runout" damage. This signal may be overridden by operators in the control room. When the noted AF21 valves

failed to open, operators manually overrode the low pressure signal to permit 22 AFW pump flow to the steam generators. The control room supervisor appropriately declared the 22 AFW pump inoperable and entered the TS 3.7. action statement (72-hour allowed outage time).

Once AFW flow was establishe.d and the main feed pumps were removed from service, equipment operators were dispatched to walk down the AFW system instrument valve lineup and verify correct positions. Operators quickly discovered that the instrument isolation valve for transmitter 2PA3449, which provides the 22 AFW pump runout protection, was closed. Within one hour of placing the AFW pumps in service, operators re-opened the instrument valve and restored the 22 AFW pump to an operable status, and initiated a corrective action request to determine the cause{s) of this even During the investigation that followed, PSE&G determined that maintenance technicians *had completed a routine calibration of the 2PA3449 transmitter on July 7, 1998. Based on personnel interviews and document reviews, PSE&G management concluded that the technician who performed the transmitter calibration failed to restore the instrument isolation valve to its proper position following the work, as required by procedure SC.IC-GP.ZZ-0003, "General Instrument Calibration for Field Devices." Additionally, a second technician assigned to independently verify that the "as-left" valve position was*-correct failed to identify the first technician's error. This independent verification is also required.

by the noted calibration procedure, as well as NC.NC-AP.ZZ-0005 {NAP-5), "Station Operating Practices." At the end of the report period, PSE&G management had not yet completed its investigation into this event nor had they developed or implemented corrective actions. PSE&G planned to issue a Licensee Event Report

{LER) describing this occurrence as required by 10 CFR 50. 7 The inspectors determined that the circumstances associated with this issue were similar to earlier station events involving inadequate control of system and component status. Specifically, NRC Inspection Report 50-272,311 /98-01 section M1.3 cited a violation of maintenance procedure requirements to ensure that emergency diesel generator fuel racks and cylinder vent petcocks are in the correct position prior to diesel operation. This issue also included a failure to complete a satisfactory independent verification of equipment status. Corrective actions resulting from this issue focused on application of PSE&G's disciplinary process to the individuals involved, maintenance procedure enhancements, and department-wide training regarding "lessons-learned" from the event. The inspectors reviewed the corrective actions stemming from several other equipment status control issues at the Salem station, including an October 1 997 failure to promptly identify a closed auxiliary building fire water header isolation valve. Preventive measures resulting from these events were also largely directed at improved training and procedure guidanc An additional previous similar event was reported in LER 50-354/97-009-00for PSE&G's Hope Creek Generating Station. In this instance, tec;hnicians failed to restore high pressure coolant injection (HPCI) system transmitter isolation valves to their correct position following a routine calibration in May 1997. This condition

was not discovered until eleven days later when the HPCI system was being operated for periodic TS surveillance testing. The Hope Creek calibration procedure also required that an independent verification of valve positions be completed. The cause of this event was attributed to personnel error, and corrective actions focused only on the conduct of "stand down" and recurring training sessions with maintenance technicians to emphasize PSE&G management expectations with respect to proce.dure adherence. This issue resulted in a cited violation of fO CFR 50, Appendix 8, Criterion XVI, "Corrective Action" in NRC Inspection Report 50-354/97-03, because this event itself was repetitive of earlier Hope Creek procedure non-compliance event The inspectors reviewed the design basis for the AFW system as documented in the Salem UFSAR to determine the potential safety consequence of the inoperable motor-driven pump. Chapter 15 of the UFSAR assumes that the post-accident AFW function is satisfied with only one motor-driven AFW pump supplying two steam generators. Therefore, the inspectors concluded that, with an initial condition of one 'motor-driven pump inoperable, the AFW function would have been fulfilled even with a single active failure of the turbine-driven AFW pump. The inspectors also reviewed the Salem Unit 2 operating logs between July 7 and July 24 to determine whether other safety systems were unavailable during the period which may have resulted in a combination of inoperable equipment that would have placed the station in an unacceptable risk condition. No unacceptable circumstances were note In spite of the apparent lack of potential safety significance or consequence, the inspectors determined that the July 7, 1998 failure to implement the 22 AFW pump discharge pressure transmitter calibration and NAP-5 procedures properly was an apparent violation of TS 6.8.1.a. Further, these procedure violations resulted in the 22 AFW pump being inoperable for 18 days, a violation of TS 3.7.1.2. Finally, the failure to maintain sufficient controls regarding the status of safety-related instrument valves appeared to be repetitive. The inspectors will review the corrective actions specified in the forthcoming LER prior to making an enforcement recommendation for this issu Conclusions PSE&G maintenance technicians failed to restore an auxiliary feed water (AFW)

pump discharge pressure transmitter to an operable condition following an instrument calibration, resulting in the undetected inoperability ofthe 22 AFW pump for eighteen day *

MS Miscellaneous Maintenance Issues M Verification of 10 CFR 50.65 ("Maintenance Rule") Requirements for Unit 1 Containment Fan Cooler Units Inspection Scope (62707, 62706) The inspectors conducted interviews with system engineering and maintenance rule program oversight personnel concerning the maintenance rule status of the Unit 1 containment fan cooler units (CFCUs). The inspectors reviewed recent Unit 1 CFCU corrective action requests (ARs), the Salem updated final safety analysis report (UFSAR), various PSE&G maintenance rule implementation procedures, Regulatory Guide 1.160, Revision 2, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and NUMARC 93-01, Revision 2, "Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" for background informatio Observations and Findings In accordance with paragraph (a)(1) of the maintenance rule, PSE&G personnel were trending and monitoring the Unit 1 CFCUs against an unavailability goal of less than 325 hours0.00376 days <br />0.0903 hours <br />5.373677e-4 weeks <br />1.236625e-4 months <br /> per cycle. Recent performance monitoring showed no adverse trends in CFCU unavailability. In addition to goal monitoring, PSE&G personnel established a reliability performance criterion of two preventable system functional failures (PSFF)

per cycle to indicate an adverse tren Based on a review of Unit 1 CFCU ARs, the inspectors noted several conditions that had not received system manager PSFF reviews within the time period set forth in procedure NC.NA-AP.ZZ-0016 (NAP-16), "Monitoring the Effectiveness of Maintenance." Additionally, some identified system functional failures did not have corresponding condition resolut.ion reports generated as' required by NAP-1 Through a brief review of maintenance rule assessment backlog data, the inspectors concluded that the noted discrepancies were not widespread among other Unit 1 and 2 systems. Although the aforementioned discrepancies were administrative in nature, the inspectors concluded that the problems indicated a lack of consistency in the "identification" stage of maintenance rule implementation. In this case, the inconsistency resulted in less than prompt identification of a PSFF and a challenge to CFCU reliability performance criteria. PSE&G maintenance rule program oversight personnel initiated corrective action requests to address these issue Conclusions PSE&G personnel appropriately monitored containment fan cooler units (CFCUs) in accordance with maintenance rule requirements. Weaknesses in syste:im functional failure identification and classification were noted for the CFCU *

Ill. Engineering

E1 Conduct of Engineering E1.1 Support to Operations and Maintenance Inspection Scope (37551 l The inspectors evaluated the level of engineering involvement in other station organization activities, primarily the operations and maintenance department Observations and Findings The inspectors frequently observed members of the engineering department staff in the field in support of system or equipment maintenance and surveillance testing activities, a recently instituted management expectation. Additionally, engineering department managers actively participated in daily interface meetings with other station organizations, frequently accepting the lead role for resolving emergent plant issues as well as long term concerns. Engineering follow up for operability determinations was usually timely and appropriate. The inspectors observed a renew~d focus on the reliability performance of several selected safety systems at the site as well. For example, recent emphasis on the apparently po0r performance of the radiation monitoring systems {RMS) at Salem led to the formation of an integrated action plan to identify, prioritize, and address all of the system deficiencies. The inspectors witnessed a comprehensive management briefing of the numerous RMS issues presented by the cognizant system engineer, indicating his thorough understanding of all the concern Several minor modifications were installed during the report period which necessitated engineering oversight to ensure that the design and licensing bases of the Salem facility were preserved. The inspectors reviewed the safety evaluations associated with several of these minor changes, including the installation of an additional support hanger on steam generator feed pump piping to mitigate excessive vibration, the application of temporary repairs to a degraded service water system valve, and the acceptance of a gouge discovered on the 11 charging pump lube oil cooler head flange. No concerns or deficiencies were identified with the safety evaluations. A more significant modification involving a change to emergency diesel generator (EDG) air start motors was promptly developed and implemented in response to indications of poor air motor performance during testing. This change, installed on both sets of air motors on all six EDG's, modified the means by which these motors are lubricated to enhance their reliability in raising the EDG's to the proper speed following receipt of a start signal. Post-modification testing of these motors indicated that the design changes satisfactorily achieved their intended purpose.

19 Conclusions Timely and appropriate engineering support of operations and maintenance was indicated by active participation in daily station interface meetings, as well as effective development of minor design changes and completion of several safety evaluation E2 Engineering Support of Facilities and Equipment E2. 1 lnservice Inspection Inspection Scope (73753)

The inspectors reviewed the lnservice Inspection (ISi) program and selected implementing procedures for Salem Units 1 and 2. Both units were in the second period of their second ten-year ISi plan interval. Unit 1 employed the 1983 edition of Section XI of the American Society of Mechanical. Engineers (ASME) code, while Unit 2 adopted the 1986 edition. Since both Salem units were operating during the week of the inspection, there vyas not any actual ISi work in progres The inspector's review encompassed a verification that the in-field ISi program and associated implementing procedures had been revised to account for~industry operating experience and changes to the ASME code. Two relief requests were examined to ensure that the bases for the requests were valid and accurat Inspection results were reviewed to verify that PSE&G had increased the sample scope when flaws were identified during examination activities. Also, personnel involved in the ISi program were interviewed, and third party audits of the ISi program were reviewe Observations and Findings Inspection Program Following a recent PSE&G engineering department reorganization, the responsibility for the development and implementation of the ISi programs for Salem and Hope Creek were combined and placed under the purview of a single individual. The ISi program manager was knowledgeable of industry ISi issues and was familiar with the specifics of each particular facility progra The inspectors reviewed the Unit 2 ISi plan and verified that it had been updated to reflect industry operating experience. ISi personnel were aware of two recent industry events, the discovery of cracks on part-length control rod drive mechanisms and reactor vessel former plate bolts, and were evaluating them for applicability to the Salem station Augmented examinations of reactor coolant system piping, as required by NRC Bulletin 88-08 "Thermal Stresses in Piping Connected to Reactor Coolant Systems,"

.and Bulletin 88-11 "Pressurizer Surge Line Thermal Stratification/ were

incorporated into PSE&G's ISi plan and completed within scheduled dates. Two relief requests, which requested relaxation of an ASME code requirement to perform a 100% surface examination on ten welds in the safety injection system, were discussed with ISi personnel. The inspectors determined that bases for these requests were vali During the recent extended plant outages, defects were identified in plant components during ISi activities. The inspectors verified that the weld examination scope was increased in accordance with ASME code requirement The Authorized Nuclear Inspector (ANI) was actively involved in the ISi program and there appeared to be a good working relationship between this inspector and PSE&G ISi personnel. The ANI indicated that he was able to witness plant modifications when necessar PSE&G was developing a containment inspection plan in response to Federal Register notice 61 FR41303, which endorsed the 1992 Edition and Addenda of Subsection IWE, "Requirements for Class MC and Metallic Liners of Class CC Components of Light-Water Cooled Plants," and Subsection IWL "Requirements for Class CC Concrete Components of Light-water Cooled Plants" of Section XI of the ASME code. PSE&G expected to complete these required inspections before the September 9, 2001 implementation date. As required by the noticer PSE&G had established processes to ensure that containment repair and replacement activities were carried out in accordance with the requirements contained in Subsections IWE and IW Qualification of Personnel Appendix C of the "Training and Certification Manual" described the certification program for non-destructive examination (NDE} personnel. The inspectors reviewed the manual and verified that the PSE&G training requirements met the guidance contained in Society of NOT-Technical Counsel document SNT-TC-1 A and UFSAR chapter 17.2, "Quality Assurance During the Operations Phase."

Oversight of NDE Activities To assess the adequacy of the ISi programs at Salem and Hope Creek, PSE&G chartered three third-party program assessments. Two of the assessm~nts were completed by consultants, while the third was performed by a combination of PSE&G quality assurance auditors and outside contractors. Taken together, all three assessments provided a comprehensive review of the Salem and Hope Creek ISi program *

Conclusions

. PSE&G implemented and maintained a satisfactory inservice inspection program at the Salem stations. The bases for selected ASME code relief requests were valid and accurate. Non-destructive examination personnel were properly trained in accordance with industry standard E7 Quality Assurance in Engineering Activities E7.1 Quality Assurance Review of Design Change Packages Inspection Scope (37551 l ES E The inspectors reviewed the. results of a recent Quality Assurance (QA) department evaluation of design change packages (DCP), and discussed several of the findings with the lead QA auditor and other QA staf Observations and Findings The inspectors noted that QA assessment No. 98-67 was conducted as part of a routine department evaluation of engineering performance. Three Salem DCPs and four Hope Creek DCPs were included in the audit scope, which in par:t consisted of an assessment of the associated 10 CFR 50.59 safety evaluations. Based upon their review, QA determined that the technical quality of the DCPs was satisfactor Further, the safety evaluations appropriately concluded that neither prior NRC approval was necessary nor that any unreviewed safety questions resulted from the modifications. QA did discover that two older, not-yet-implemented DCPs had not been revised to account for related system changes resulting from the implementation of newer DCPs. QA also identified several minor administrative issues. Six corrective action requests were generated to ensure that QA's various findings would be addressed. Based on discussions with the responsible QA staff members, the inspectors were confident that the noted findings and assessments were valid and that increased QA monitoring in this area was not warrante Conclusions The Quality Assurance department conducted a thorough audit of several station design change packages and associated safety evaluation Miscellaneous Engineering Issues (Closed) LER 50-272/96-028-00: Operation of the Salem Units in an Unanalyzed Condition Due to Low Component Cooling Water Flow Inspection Scope (92700)

The inspectors reviewed the events and verified associated corrective actions described in the subject Licensee Event Report (LER).

22 Observations and Findings This LER details two issues involving the component cool.ing (CC) water syste The first issue concerned a discrepancy between installed control room residual heat

. removal heat exchanger (RHRHX) CC flow indicators and temporary flow meters used during CC pump inservice testing. Control room indicators incorrectly displayed greater flow rates than the more accurate temporary test meters. This condition resulted from improper calibration of the control room flow indicators *

following initial installatio All Unit 1 and 2 RHRHX CC flow indicators have since been re-calibrated to correct this condition.. This failure to ensure that safety-related control room indicators were properly calibrated is a violation of the measuring and test equipment requirements of 10 CFR 50, Appendix 8, Criterion XII. However, this failure constitutes a violation of minor significance and is not subject to formal enforcement actio The second issue documented in the LER involved the use of a non-safety related temperature control valve (CC71} in the safety-related CC system. PSE&G determined that the most limiting CC system single failure, combined with an assumed initial condition of CC71 failed in the open position, would result in a CC pump "runout" condition. This would in turn cause less than required CC flow to safety-related equipment during accident conditions. However, PSE&G's subsequent evaluation determined that the CC pumps could operate -reliably in a runout condition, and that adequate heat removal could be achieved by placing an additional CC pump in service. PSE&G attributed the cause of this issue to an inadequate review of emergency operation design requirements during initial plant licensing. This failure constituted a violation of the design control requirements of 10 CFR 50, Appendix 8, Criterion Il To correct this condition, PSE&G upgraded the Unit 1 and 2 CC71 valve actuators and associated control circuitry to nuclear safety-related equipment standards. The associated valve control circuitry was also modified to provide automatic and fail-safe close features. The inspectors reviewed portions of the CC71 valve upgrade design change packages and did not identify any problems. The inspectors also verified that appropriate procedures have been implemented to test the safety function of the CC71 valves. This non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll. of the NRC Enforcement Policy. (NCV 50-272/98-06-03)

E (Closed) LER 50-272/98-001-00: Auxiliary Feed Water Pump Internal Flooding Protection Installed Incorrectly Inspection Scope (92700)

The inspectors reviewed the events and corrective actions described in the subject Licensee Event Report (LER).

c.

Observations and Findings During a Unit 1 system readiness walkdown, a system manager observed an improperly installed flood gate which protects the turbine-driven auxiliary feed water pump from the effects of a pipe rupture in the auxiliary building pipe alley. PSE&G personnel concluded that the flood gate was not installed properly during original plant construction. The inspectors determined that this configuratiOn error was a violation of 10 CFR 50 Appendix 8, Criterion Ill "Design Control". PSE&G was unable to determine the exact cause of this condition, since the flood gate's maintenance history was not available. No safety consequences resulted from this event, and the inspectors concluded that PSE&G's analysis, which demonstrated limited safety implications, was reasonabl To correct this condition, PSE&G re-installed the Unit 1 flood gate properly, and verified appropriate installation of the similar Unit 2 flood gate. Additionally, recurring preventive maintenance tasks for both Unit 1 and 2 pipe alley flood gates were being developed. The inspectors verified the completion and the progress of the noted corrective actions through a review of maintenance work orders and corrective action requests. The inspectors concluded that the improper installation of the noted flood gate constitutes a violation of minor significance and is not subject to formal enforcement actio Conclusions PSE&G's corrective actions to address an improperly installed auxiliary feed water pump flood protection gate were adequat E (Closed) VIO 50-272,311 /98-001-1 O:Failure to Promptly Identify and Correct Degradation in Service Water System Inspection Scope (37750, 92702) The inspectors reviewed PSE&G's April 29, 1998 violation response letter and verified selected corrective actions for the issues involve Observations and Findings This violation involved a failure to take prompt actions to identify and correct the cause of service water system (SWS) biological fouling problems. PSE&G acknowledged the NRC's findings and completed a comprehensive root cause assessment of the circumstances leading to the violation. This assessment concluded that a lapse in engineering oversight of the SWS Reliability Program, governed by nuclear department procedure NC.NA-AP.ZZ-0039(0) (NAP-39), was largely responsible for this issue. Specifically, PSE&G determined that the engineering group responsible for implementing NAP-39 had been eliminated in a recent department reorganization. Additionally, the assessment determined that service water strainer filter elemerit locking rings were installed incorrectly, resulting in their premature failure and loss of associated filter media, which in turn permitted

excessive debris from the Delaware River to enter the *sws. Lastly, technicians identified one SWS strainer that had an excessive filter basket-to-wearing ring clearance, which also allowed debris to enter the syste The inspectors verified that the corrective actions outlined in the response letter were implemented, which included the assignment of a new SWS Reliability Program manager, revision of the SWS strainer maintenance procedure to clarify filter m~dia locking ring installation guidance, and development of a new abnormal operations department procedure which specifies operator actions to be taken when river debris levels are excessive. All of the Salem Unit 1 and 2 SWS strainers were systematically removed from service for inspection and locking ring replacement, and all service water-cooled heat exchangers were evaluated for acceptable performance by flow testing and/or internal examination. Several of these follow up actions were also documented in NRC Inspection Report 50-272&311 /98-0 Conclusions PSE&G implemented extensive corrective actions to address deficiencies in both service water system maintenance activities and system reliability performance monitoring and oversigh IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Salem Solid Radioactive Waste Processing Inspection Scope (86750) The inspectors conducted plant tours to review the solid radwaste processing practices with respect to UFSAR descriptions and radwaste sampling, characterization, and waste classification requirements. These tours included the radwaste liquid filtration and deionizing system located adjacent to the radwaste trucklock are Observations and Findings Salem waste liquids were processed through charcoal and bead resins in a Duratek TUF System (DTS) water processing skid. As a resin or charcoal vessel becomes depleted, it is sluiced into a polyethylene liner in stratified layers requiring composite samples to be collected from each; these are used as a representative sample f~r waste characterization and classification purposes. Since August 1997, PSE&G has used. an additional radwaste filtering system upstream of the DTS water processing skid. This Tubular Ultra-Filtration System (TUFS) prefilters the waste water and was periodically {once per. week) backwashed and discharged into the same polyethylene liner used for resin and charcoal discharges. The excess water was removed as necessary. Although technicians collected resin and charcoal samples

during vessel discharges, to date the TUFS wastestream has not been sampled or characterized. At the time of the inspection, the polyethylene liner used to collect the. solid wastes was approximately 2/3 full and dated. from before the startup of the TUFS equipment. PSE&G has been investigating methods for obtaining a representative sample of the polyethylene liner, however, this effort has not yet

.been successful. Establishing a method*for sampling the TUFS filtrate discharge will be tracked a~ an inspector followup ite (IFI 50-272&311/98-06-04)

After a polyethylene liner becomes full and ready for final dewatering, PSE&G utilized a procedure based on a vendor's NRC-approved process control program (PCP) that ensures less than 1 % free standing water is present in the liner.. The procedure utilizes a bead resin liner (pump out piping orily in the bottom). PCPs for dewatering powdered resin wastes utilize internal piping at more than one level in the liners. The current practice mixes bead resin/charcoal wastes with backwashed filtrate wastes. The vendor's dewatering PCP had been revised to account for the TUFS wastes to be dewatered in a bead resin liner to ensure less than 1 % free standing water criteria is maintained. PSE&G was pursuing a review of the vendor's dewatering PCP. This will be tracked as an inspection followup ite (IFI 50-272&311/98-06-05) Conclusions Salem solid radioactive wastes were effectively sampled, packaged, and dewatered in accordance with requirements, however, the need to update the waste characterization and packaging program to include the filtrate wastes from the tubular ultra-filtration system prior.to waste shipment remain R 1. 2 Solid Radioactive Waste Storage Inspection Scope (86750)

The inspectors toured Salem plant areas to observe the condition of radioactive material storage areas. The condition of the common site Low Level Radioactive

Waste Storage Facility (LLRWSF) was also evaluate Observations and Findings Limited amounts of stored contaminated equipment were properly maintained and controlled. There was an inventory of 38 spent cotton filters and six detectors containing special nuclear material located in the Salem high radiation radwaste sto.rage area, which consisted of less than one polyethylene liner shipment of accumulation. This high radiation storage area was kept locked and the inspectors verified that the inventory was accurat The LLRWSF did not contain any Salem stored radioactive wastes.

26 Conclusion PSE&G effectively limited the amount of stored contaminated equipment and radioactive waste R3 RP&C Procedures and Documentation

'

R3. 1 Radioactive Material Shipment Procedures Inspection Scope (86750)

The inspectors reviewed the following procedures with respect to Department of Transportation and NRC radioactive material transportation regulation *

Salem Process Control Program, Rev. 2

NC.RP-RW.ZZ-0906(0), Rev. 2, "Shipment of Radioactive Material"

NC.RS-RW.ZZ-0911 (0), Rev. 0, "Use of the 14-210 or 14-215 Radioactive Material Shipping Package"

NC.RPTl.ZZ-0930(0), Rev. 1, "Interim Low Level Radioactive Waste Transfer and Storage"

SC.RP-RW.ZZ-0913(0), Rev. 1, "Laundry Container Preparation for Shipment"

SC.RP-RW.ZZ-0902(0), Rev; 0, "Radioactive Waste Sampling and Classification"

SC.RP-RW.ZZ-0901 (0), Rev. 5, "Receipt and Inspection of Radioactive

Material"

SC.RP-RW.ZZ-0806(0), Rev. 1,. "Radioactive Material Packaging"

SC.RP-Tl.ZZ-0804(0), Rev. 3, "Labeling and Control of Radioactive Material" Observations and Findings Several previous radioactive material transportation procedures were effectively combined and organized into a common procedure. Also, radioactive waste sampling and shipping procedures were upgraded to indicate that they implement the station process control program required by technical specifications. No significant procedure discrepancies were identifie Conclusions Salem radioactive waste processing and radioactive material shipping procedures were of good quality and effectively implemented regulatory requirements.

R5 Staff Training and Qualification in RP&C R Radioactive Material Shipment Training Inspection Scope (86750)

Radioactive material shipping lesson plans and training atten~_ance documents were reviewed, and interviews with cognizant PSE&G individuals were conducted with respect to 49CFR172 Subpart H and NRC IE Bulletin No. 79-19 requirement Observations and Findings For both the Hope Creek and Salem stations, radioactive material shipments were accomplished by two authorized shippers while eight quality verification inspectors were available to provide independent reviews of each outgoin~ radioactive shipment (except for excepted package shipments). The inspectors verified that the records for all ten of these individuals indicated that their required training was current (i.e. completed within the last three years). PSE&G's in-house training program contained only limited Department of Transportation (DOT) regulation content, however, the manager of technical services indicated that this training course would be alternated with a vendor course covering all DOT and NRC radioactive shipment regulations on a biennial basi. ~ Conclusions All principal radioactive material shipment personnel fulfilled the regulatory training requirement R7 Quality Assurance in RP&C Activities R7. 1 Radioactive Material Shipping Audit Inspection Scope PSE&G Quality Assurance (QA) department personnel completed a radioactive material shipping program audit on July 7, 1998; the inspectors reviewed a draft report of this audit. In addition, radioactive waste proce.ssing and transport vendor audits were reviewed in accordance with IE Bulletin 79-19 requirement Observations and Findings QA audit No.98-152 consisted of two outside utility technical speCialists and a team of auditors. The audit was of good scope and depth, and findings were effectively communicated for resolution. Several offsite vendors supply transfer, packaging and transport of PSE&G's radioactive waste and fall within the audit requirements of IE Bulletin 79-19. These vendors include: Molten Metal Technology, Frank Hake, Hittman Transportation Services, Tri-State Motor

Transport, and Kindrick Trucking. PSE&G's recent QA audit of the radioactive

.

material shipping program identified a long standing issue with respect t insufficient vendor audits. Corrective actions have been implemented to ensure that the applicable radwaste vendors are periodically audited. All of the above mentioned vendors have either been audited by the Nuclear Utilities Procurement Issues Council or are scheduled for an audit within the next six month Each radioac!ive material shipment with radioactivity exceeding excepted package concentrations require an independent review of the shipment by a quality verification inspector. For each shipment record reviewed, the inspectors noted appropriate radioactive shipment verifications were complete Conclusion Quality Assurance oversight of the radioactive material shipment program was*

effective through performance of a program audit and independent shipment verification *

RS Miscellaneous RP&C Issues R8.. 1 (Closed) URI 50-272,311 /97-012-01 :Lack of Timely Completion of a Design Change Package for Meteorological Monitoring Instrumentation

...

This issue, which questioned the process for maintaining configuration control for plant equipment following design modifications, was identified during an NRC inspection of the radioactive effluents monitoring program. The inspectors subsequently concluded that this issue involved an isolated failure to implement the requirements of PSE&G's design change process. Additionally, because the meteorological monitoring program is not within the scope of 10 CFR 50 Appendix B quality assurance criteria, the lack of timely implementation of this change package did not constitute a violation of regulatory requirements. This issue was also described and closed in NRC Inspection Report 50-354/97-07for PSE&G's Hope Creek statio P2 Status of EP Facilities, Equipment, and Resources P Temporary Loss of Alert Notification System Sirens Inspection Scope (71750) The inspectors reviewed PSE&G's response to an event involving the temporary loss of 30 Alert Notification* System (ANS) sirens in Ne*w Jerse Observations and Findings On July 8, 1998, a non-PSE&G controlled offsite electrical substation failure resulted in the loss of power to 30 of the 34 ANS sirens located in New Jersey for approximately two hours. Upon discovery, the control room operations supervisor correctly made a one-hour report to the NRC in accordance with the Salem Event

Classification Guide, Section 11. 7.1.b. Siren maintenance personnel tested the affected sirens when power was restored to verify proper operation. 29 of the 30 sirens were restored within about two hours. One siren was not immediately restored due to a DC battery failure, but was quickly repaired and tested within about five and a half hours of the initial even * Conclusions PSE&G appropriately responded to the temporary loss of 30 alert notification sirens in New Jersey,* which included the timely completion of a 10 CFR 50. 72 one-hour non-emergency event repor SS Miscellaneous Security and Safeguards Issues S (Closed) VIO 50-272,311/E97-422-01013: Safeguards Event Log Not Maintained Complete and Accurate Inspection Scope (71750, 92702)

The inspectors reviewed PSE&G's May 18, 1998 violation response letter and verified selected corrective actions for the issues involve Observations and Findings This violation involved a willful failure to maintain complete and accurate information associated with an entry in the safeguards event log. Specifically, security personnel made a log entry which indicated that compensatory measures were established within the required ten minutes following a failure qf the security computer, when these measures were not actually in place for eighteen minutes. In their response, PSE&G management agreed that the information recorded in the log was inaccurate, but did not agree with the NRC's conclusion that the improper log entry was entered deliberately. PSE&G attributed the cause of this issue to poor work practices and procedures, stemming from "an unhealthy culture" within the security department. Corrective actions included personnel disciplinary measures, changes in the department managers and supervisors, and enhancements to procedures. The inspectors determined that these actions were reasonable given the nature of the issues involved, and verified that all of actions were completed in a timely manner. No further similar issues have been identified subsequent to this even Conclusion PSE&G implemented timely and appropriate corrective actions for a self-identified issue invoiving the failure to maintain a complete and accurate safeguards event log.

V. Management Meetings X 1 Exit Meeting Summary The inspectors presented their findings to members of PSE&G management at the conclusion of the report period on August 5, 1998. PSE&G management acknowledged the findings presente The inspectors asked whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie X2 Management Meeting Summary On July 1, 1998, Mr. H. Miller, NRC Region I Regional Administrator, and Mr. S. Collins,

. Director of Nuclear Reactor Regulation at NRC Headquarters, toured the Salem facility and met with members of PSE&G senior management on-site. This visit was conducted in preparation for the July 1998 NRC Senior Management Meeting, at which Salem plant performance was discussed in detai *

IP 37550:

IP37551:

IP 40500:

IP 61726:

IP 62706:

IP 62707:

IP 71707:

IP 71750:

IP 73753:

IP 86750:

IP 92700:

IP 92702:

IP 92901:

IP 92902:

IP 92903:

IP 92904:

IP 93702:

Opened

INSPECTION PROCEDURES USED Engineering Onsite Engineering Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems Surveillance Observations Maintenance Rule Inspection Procedure Maintenance Observations Plant Operations Plant Support Activities lnservice Inspection Occupational Radiation Exposur Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities Followup on Corrective Actions for Violations and Deviations Plant Operations Followup Maintenance Followup Engineering Followup

. Plant Support Followup Event Followup ITEMS OPENED AND CLOSED 50-272; 50-311198-06-04 IFI Tubular Ultra-Filtration System (TUFS) solid waste stream sampling method to be determined. (Section R1.1)

50-272; 50-311198-06-05 Opened/Closed 50-311198-06-01 50-272&31-1 /98-06-02 50-272&311 /98-06-03 IFI TUFS dewatering process control program to be reviewed.. (Section R1.1)

NCV Failure to ensure the adequacy of plant drawing revisions. (Section 08.4)

NCV Failure to implement the requirements of the safety tagging program. (Section M1.2)

NCV Operation of Salem units in an unanalyzed condition due to low component cooling water flow. (Section E8.1)

Closed 50-272&311 /97-12-01 50-272&311 /97-12-02 50-311/97-21-01 50-272&311/E97-422-01013 50-272&311/98-01-10 50-272/96-028-00 50-311 /97-004-00 50-311/97-012-00 50-311 /97-013-00 50-272/98-001-00 50-272/98-006-00

URI Lack of timely completion of a design change package for meteorological monitoring instrumentation. {Section R8.1)

VIO Inadequate corrective actions for configuration control deficiencies and a degraded auxiliary feedwater pipe. {Section 08.1)

VIO Failure to comply with procedures for equipment status control. {Section 08.6)

VIO Safeguards event log not maintained complete and accurate. {Section S8.1)

VIO Failure to promptly identify and correct degradation in service water system. {Section E8.3)

LER Operation of the Salem units in an unanalyzed condition due to low component cooling water flow. {Section E8.1)

LER Failure to comply with technical specification action statement diesel generator start, and inadequate surveillance testing. (Section 08.2)

LER Entry into TS 3.0.3 due to inoperability of two OTDT channels. {Section 08.3)

LER Entry into TS 3.0.3 due to two inoperable pressurizer level channels. {Section 08.4)

LER Auxiliary feed water pump internal flooding protection installed incorrectly. {Section E8.2)

LER Engineered safety feature actuation of 11 and 1 2 auxiliary feed water pumps. {Section 08.5)

AFW ANI ANS A Rs ASME CARB cc CFCU eves DCP DOT DTS EOG GL HPCI IFI ISi LER LLRWSF MMIS NAP NOE NRC OD OPDT OTDT PCP PDR PSE&G PSFF QA RCL RHR RHRHX RMS RP& SEC SORC SSW sws TRIS

. TS TSAS TSSIP TUFS UFSAR voe

LIST OF ACRONYMS USED Auxiliary Feed Water Authorized Nuclear Inspector Alert Notification System Action Requests American Society of Mechanical Engineers Corrective Action Review Board Component Cooling Containment Fan Cooler Unit Chemical and Volume Control System Design Change Package U.S. Department of Transportation Duratek TUF System Emergency Diesel Generator Generic Letter High Pressure Coolant Injection Inspector Followup Item *

lnservice Inspection Licensee Event Report Low level radioactive waste storage facility Maintenance Management Information System.

Nuclear Administrative Procedure Non-destructive Examination Nuclear Regulatory Commission Operability Determination Overpower-Differential Temperature Overtemperature-Differential Temperature Process control program Public Document Room Public Service Electric and Gas Preventable System Functional Failures Quality Assurance Reactor Coolant Loop Residual Heat Removal Residual Heat Removal Heat Exchanger Radiation Monitoring System Radiological Protection and Chemistry Safeguards Equfpment Cabinet Station Operations Review Committee Station Service Water Service Water System Tagging Request and Inquiry System Technical Specification Technical Specification Action Statement Technical Specification Surveillance Improvement Project Tubular Ultra-Filtration System

. Updated Final. Safety Analysis Report Volts DC

v t e Inspection Report - Salem - 1998006
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \|
1998 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 7(0) 8(0) 9(0) 11(0) 12(0) 80(0) 81(0) 99(0) 12(0) Security 202(0) Operator Exams 301(0) 302(0) Emergency Planning Other

IR 05000272/1998006

Text

REGION I

Navigation menu

Search