IR 05000311/1987003
| ML20210V393 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/06/1987 |
| From: | Norrholm L, Roxanne Summers NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20210V384 | List: |
| References | |
| 50-311-87-03, 50-311-87-3, IEIN-87-001, IEIN-87-1, NUDOCS 8702190011 | |
| Download: ML20210V393 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-311/87-03 Docket Nos.
50-311
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License Nos.
OPR-75 Licensee:
Pubite Service Electric and Gas Company 80 Park Plaza Newark, New Jersey 07101 Facility Name: Salem Nuclear _ Generating Station - Unit 2 Inspection At: Hancocks Bridge,_New Jersey l
Inspection Conducted: January _12, 1987 - January 23, 1987 l
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l Inspectors:
T.J.No
, Senior Resident Inspector K. H: 3(bs n, Rest e t Inspector Reviewed by: Y b
RQ.'%'P/ojrc,tsSectionNo.20,ORP
~ FrolecTEngind4r
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l Approved by:
Jh.1 Norrholm, Chief,7 eactor Projects iGlo
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i Secti'on No. 20, Projects Branch No. 2, DRP Inspection Summary:iuar l
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Inspections on Jai
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fmber 56;flT7if7_r03)-~y-,1987 - J_anuary 23,~1987 (Inspection Rep ~ ort ~
Areas Inspected:
This special report documents the resident inspectors'
review of IEoiisco actions taken as a result of the identification, by the licensee, of Salem Unit 2 operation outside the design basis analysis as described in IE Information Notico 87-01.
The inspection involved 24 inspector hours by the restdont NRC inspectors.
Results: One apparent violation was identiflod as described in paragraph 4
'o~f ~tIII's' report.
III 90 l1 AUC Cft (I UL' I O
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DETAILS 1.
Introduction 1.1 The Residual Heat Removal (RHR) System at Salem serves in two capacities.
As an RHR System the system utilizes two pumps with two coolers and their associated valves to cool the reactor following a shutdown of the Reactor Coolant System (RCS).
The system can be considered two separate subsystems.
As part of the Emergency Core Cooling System (ECCS) the RHR system
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utilizes two pumps (considered low head safety injection pumps)
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valves and piping to deliver water from the refueling water storage
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tank or containment sump to four cold Icgs of the RCS.
The system cannot be considered two separate subsystems as far as injection into
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the four cold legs is considered.
However, one RHR pump may be taken
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out of service in accordance with Technical Specifications.
1.2 On January 13, 1987, Salem Unit 2 was operating at 95% power with the
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RHR system available as ECCS when, following review of IE Informa-
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tion Notico 87-01, the licensee discovered that the RHR system i
l alignment associated with an RHR pump and valves tagged for mainte-
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nance possibly placed the unit in a condition outside of the ECCS design basis analysis.
This report discusses the licensee's actions
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l and NRC followup.
2.
Persons Contacted I
Within this report period, interviews and discussions were conducted with
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members of Itcensee management and staf f as necessary to support inspec-
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tion activity, i
3.
0$ uments Reviewed
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Salem Unit 2 Technical Specifications
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Salem - UFSAR, Revision 5, dated July 25, 1966
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Control Room Operator's Logs January 12, 1987 to January 14, 1987
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Integrated Operating Procedure 10P-2 Cold Shutdown to Hot Standby
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SP(0)4.4.7.2.1(d) Emergency Core Cooling System - ECCS Subsystems
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Tagging Request No. 41273 dated January 13, 1987
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Temporary / Partial Release No. 41273-T0 dated January 13, 1987
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Temporary / Partial Release No. 41273-TI dated January 13, 1987
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Salem - FSAR, Amendment 43, dated March 6, 1980
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PSE&G..chnical Training Manual
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Nuclear Network 1986 Summary dated October 3, 1986
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Operations Department Information Directive 87-02 dated January 14,
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1987 Fact Finder on IE Notice 87-01 (Draf t, Compiled by Licensee task
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force)
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4.
Description of Event On January 12, 1987, Salem Unit 2 was in Mode 1 and operating at 95%
reactor power.
No. 21 RHR pump was run in accordance with Operations Directive - 10 to prove the pump operable prior to removing the No. 22 RHR pump (redundant train) from service.
At 11:42 p.m. on January 12, 1987, the licensee removed the No. 22 RHR pump from service and entered Unit 2 Technical Specification 3.5.2.d Action (a) for inoperability of one of two RHR pumps.
The Action State-ment requires return to operability of the RHR pump within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The licensee's intent was to take advantage of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time frame afforded by the action statement to perform preventive maintenance which consisted of repacking 28 valves in the No. 22 RHR flowpath with Chesterton packing. At approximately 8:00 a.m. on January 13, 1987, Group Tagging Request No. 41273 was completed which made certain valves in the RHR flowpath inoperable.
Two of these were 22SJ49 (RHR discharge to Nos. 22 and 24 RCS cold legs) and 22RH19 (RHR loop crosstle valve).
The maintenance department then comrenced removing the packing from the valves designated to be repacked.
From a production standpoint, it was decided to unpack all the valves first, then repack them with the Chesterton packing.
Three crews of two people each were assigned to this work. At approximately 5:00 p.m.
the Assistant General Manager (AGM) - Salem received in his mail IE Informaticn Notico (IN) No. 87-01 "RHR Valve Misalignment Causes Degrada-tion of ECCS in PWR$" dated January 6, 1987.
The IN describes a lineup in which closure of certain valves in the RHR system would result in isola-
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tion of RHR flow to two of the four RCS cold legs. This lineup could put the facility in an unanalyzed condition if the licensing basis for ECCS analysis assumed that all four RCS cold lejs are being supplied by at least one RHR pump.
Following review of the IN and recognizing that RHR work was being done in Unit 2, the AGM contacted Operations department personnel and directed them to determine the applicability of the IN to Salem Unit 2.
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At 5:33 p.m., the licensee determined that Unit 2 RHR system was configured as described in the IN (i.e. RHR flow to two of the four RCS cold legs was isolated). However, the licensee did not know if the design bases assumed injection to all 4 cold legs. As a precautionary measure, the licensee commenced a load decrease of Unit 2 in accordance with Technical Specification 3.0.3 which requires placing the unit in a mode in which the specification does not apply when an LCO is not met and the condition is not provided for in the associated action statement (s). At 5:44 p.m. the licensee made a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> notification to the NRC via ENS in accordance with 10 CFR 50.72(b)(1)(ii)(0) due to the plant being in a condition that is outside the design basis.
The call was made as a pre-cautionary measure in that the 11censeo did not know at the time whether the design bases analysis included RHR injection into all four loops.
In order to return the RilR system to a configuration which would provide t
flow to all four RCS cold legs (with one RHR pump tagged out), the
Itcensee determined that valves 22SJ49 and 22RH19 and their associated i
breakers needed to be put back to their normal alignment. Valvo 22RH14 was chosen as an alternate blocking point to 22SJ49 which needed to be realigned (opened). At this point, 20 of the 28 valves had been unpacked,
six of which had to be repacked to return the valves and the RHR flowpath
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to operability.
The maintenanco crews (3 crews /2 people each) were re-
directed to install the Chestorton packing into these six valves in as timely a manner as possible.
At approximately 7:29 p.m., the repacking of the six valvos was completed and Temporary / Partial Tagging Roloase No. 41273-T0 was approved by the Unit 2 Shift Supervisor to return valvos 22SJ49, 22RH19, their associated breakers, and drain valvo 22RH70 to their normal position returning the RHR flowpath to operable status.
By 8:40 p.m., the RilR flowpath to all four RCS cold legs was restored.
The load reduction of Unit 2 (reactor power at 60%) was terminated and the
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licensee exited Technical Specification 3.0.3.
The inspector attended two Itconseo meetings rogarding IN 87-01. One j
involved a conferenco call with Westinghouse engincors and the other was a plant staf f meeting. Applicability of IN 87-01 to the Salem ECCS design bases was discussed along with followup actions to ensure future compli-
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ance once the design bases woro confirmed.
Following the meetings, the
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AGM formally notified the NRC via the resident inspector that Unit 2 had
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in fact operated outside of the design bases assumed in the Salem FSAR,
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whilohavingRHRinjectiontotwoRCSloopsisolated(injectiontoall l
four loops required) for the timo period the 22SJ49 and 22RH19 valvos were tagged closed.
Further, the licensoo notified the inspector that i
Technical Specification Survoillance 4.5.2 which demonstrates ECCS l
operability by verifying valvo positions was also violated during this timo portod.
The surveillance test, which involves in part verifying that i
valve 22SJ49 is open with power to the valve operator removed, was per-formed twice by two different reactor operators (RO).
However, the valvo
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was closed and the breaker open as discussed previously. Both R0's, in performing the surveillance, noted in the logs that the valve was not in
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its required position.
The two RO's and the SR0 (Shift Supervisor) who originally authorized the tagging request failed to recognize that closing the 22SJ49 valve was in violation of the Technical Specifications.
Technical Specification Limiting fondition for Operation (LCO) 3.5.2 requires in Modes 1, 2, and 3 that two independent emergency core cooling system (ECCS) subsystems be operable with each subsystem comprised in part
of a residual heat removal (RHR) pump and an operable flow path.
Technical Specification LCO 3.0.3 requires that when a Limiting Condition for Operation and/or associated action requirements cannot be satisfied, the reactor be placed in at least hot standby within one hour.
The operability for the RHR system flow path for a loss of coolant acci-
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dent is described in Salem Updated Final Safoty Analysis Report (FSAR)
l Section 6.3 which indicates that RHR flow will be injected into all four
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cold legs of the reactor coolant system.
On January 12 and 13, 1987 while in Mode 1, for twenty hours and fifty eight minutes, portions of two ECCS subsystems (the RHR system) were inoperable when valve 22SJ49 was closed. With valvo 22SJ49 closed, the
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flow path for RHR cold 109 injection is to only two of the four reactor coolant system cold legs.
This is an apparent violation of Technical Specifications (311/87-03-01),
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Licensee Followup i
The licensee identified the following items to investigate and resolve as
necessary.
5.1 The licensee became aware of the problem as a result of receipt and
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review of IN 87-01. According to the IN, this problem was first identified in May, 1985 and occurred twice sinco then.
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the licensee decided to investigato whether they may have received information earlier from other sources such as INP0 or Westinghouse i
that could have alerted them to the problem.
A Nuclear Network 1986 Executive Summary dated October 3, 1986 listed i
Nuclear Department, Salem and Hopo Crook management personnel for
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distributton.
This document was distributed within the licensee's organization for informational purposes.
The summary included an
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INPO Notepad description of an ovent which occurred on September 12,
j 1986 at 0.C. Cook plant where intermediate head safety injection crosstio valves were closed in support of maintenanco activities, isolating injection to 2 RCS cold legs and rendoring the plant out-side of its design basis.
The document also addressed the RHR
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system as being in the samo category.
It appears that the licensoo
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i did not recognize the O.C. Cook event as applicable to the Salem units.
Following the Salem event, the licensee called the D.C. Cook plant and discussed the similarities of the events. As a result, the licensee is in the process of drafting a letter to NRR to take similar actions as D.C. Cook. These actions would allow certain of the isolation valves and crosstie valves to be closed for testing purposes provided they are re-opened within one hour.
The licensee also identified that injection into four loops is also required in Mode 4 operat.fon.
5.2 The licensee reviewed operating and survoillance procedures relative to ECCS to determine whether performance of the proceduros would result in misalignment of the RHR system valves and isolation of cold leg injection flow paths with the following results.
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Every three months the RH19 and SJ49 valves are stroke timo tested to meet the surveillanco requirements for inservice testing of ASME components spectfied in Technical Spectfication 4.0.5.
As a result, the valves are cycled closed for short periods of timo.
The valves are tested in Modos 1 through 4.
Ontwolvemonth(Unit 1)andninemonth(Unit 2) intervals,during l
RCS pressure boundary check valve testing the SJ49 valves are closed to prevent the Rufueling Water Storage Tank from draining to the waste system through the test lines while testing the SJ56 valves.
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Pressure boundary testing is normally performed in Mode 4, but had i
been dono in Mode 3 in the past.
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Vortfication of ECCS Subsystem valvo alignment is performed prior to
r entering Mode 4.
The procedure requires that one of the SJ49 valvos
be vertflod open and does not address the verification of the post-
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tion of the RH19 valves.
This indicates that misalignment of thoso
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l valves could occur in Modo 4.
SurveillancoProceduroSP(0)4.5.3.1
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I was revised to requiro both Ril19 and SJ49 valves be open prior to i
entry into Mode 4.
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5.3 The licensco reviewed past maintenance or surveillance history
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i records to datormino how many timos and for how long they may havo l
boon in the unanalyzed condttion previously.
The licensoo reviewed availablo Incident Reports and tagging computer
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i records which indicate that the RHR system valvos have been misaligned in the past. However, the records did not contain
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spectfic information as to the number and longths of timo the
unanalyzed condition may have existed.
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5.4 The Itconseo investigated operator undorstanding of the RHR system design basis as part of CCCS and the doftnition of oporability relativo to Technical Specification Survoillance 4.5.2.
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SR0's and RO's questioned by both Itcensee management and the inspectors stated that they thought each " train" of RHR consisted of one pump, one heat exchanger, and injection into two RCS cold legs.
RHR function as part of ECCS does not appear to be focused on in training as much as the residual heat removal function of the system for shutdown cooling where discharge can be into only two of the cold legs. Neither the UFSAR nor the Technical Specifications clearly state that a single RHR flowpath (i.e. one RHR pump) requires
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injection into all four cold legs.
The licensee issued an Operations Department Information Directive to all licensed operators which contained a copy of IN 87-01 and a Technical Specification interpretation defining the requirements for an operable flowpath for RHR as an ECCS subsystem. The directive is an interim measure until the Technical Specifications are clarified.
6.
NRC Followup.
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The inspectors reviewed licensee documentation, held discussions with licensee personnel, and attended licensee mootings and conference calls with Westinghouse (NSSS) in followup of the event and licensee actions.
The following are items that have not yet besn resolved by the licensee.
The inspectors will follow itcensee actions concerning these items as they are completed.
6.1 Address outstanding task force recommendations denoted in the Fact Finder report as follows:
Engineering should review all Technical Specifications assoct-
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ated with ECCS flow paths.
These Technical Specifications should be revised to clearly identify what is required and what action should be taken if one or more of the four injection paths become inoperable (311/87-03-02)
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Operations should issue an interpretation on Technical Spect-
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fication 3.5.2 as an interim measure untti the Technical Specification is changed.
(Complete as discussed in Section 5.4)
PS&G Licensing should pursue obtaining approval from the NRC to
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allow entry into Technical Specification 3.0.3 for testing purposes.
(311/87-03-03)
Engineering should review the UFSAR and revise as necessary to
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insure that it states clearly that each ECCS Subsystem must be capable of injecting to all four cold legs.
(311/87-03-04)
6.2 Determine whether the Operating Fxperience Review Program encompassed the notepad notice concerning the O.C. Cook incident.
(311/87-03-05)
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6.3 Address the licensed operator training program relative to clarifying l
RHR design bases when functioning as an ECCS subsystem.
(311/87-03-06)
The inspectors have no further questions at this time.
7.
Exit Interview At periodic intervals during the course of the inspection, meetings were held with senior facility management to discuss the inspection i
scope and findings. An exit interview was held with licensee
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l management at the end of the reporting period. The licensee did not l
identify 2.790 material..
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Attachments 1.
Valves To Be Repacked With Chesterton Packing l
2.
Residual Heat Removal System Diagram
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Attachment i Valves To Be Repacked With Chesterton_ Packing 22RH18 22RH44 22RH17 22RH56.X 22RH15.X 22RH16 X 22RH13 22RH9
.X 22RH14.X 22RH39 X 22RH10 22RH38 X 22RH32 X 22RH37 X 22RH11 X 22RH31 X 22RH6 22RH35 X 22RH55 X 22RH29 2RH78 X 22RH30 X 22RH70 22RH40 22RH7 X
22RH34 X 2RH71
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X Unpacked
. Repacked to restore RHR operability Note:
The valves shown on Attachment 2 RHR System Diagram are main line isolation valves.
Vents, drains, and instrument line isolation valves that are listed above are not shown on the diagram.
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