ML18082A181
| ML18082A181 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/10/1980 |
| From: | Schneider E Public Service Enterprise Group |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8004160246 | |
| Download: ML18082A181 (2) | |
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Frederick W. Schneider Vice President Pub I ic Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201 /430-7373 Production Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch 2\\pril 10, 1980 Off ice of Inspection and Enforcement
.. Region 1 U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Brunner:
NRC INSPECTION 50-272/80-05 SALEM NO. 1 UNIT In reply to the violation addressed in Appendix A of Inspection 50-272/80-05 dated March 19, 1980 we hereby submit the following response:
Description of Violation Technical Specification 3.0.4 states, "Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION state-ments unless otherwise excepted."
Technical Specifi-cation 3.5.4.2 states, "At least two independent chan-nels of heat tracing shall be OPERABLE for the boron injection tank and for the heat traced portions of the associated flow paths.
- APPL!CAB.IL.ITY:
Modes l, 2 and
- 3."
Contrary to the above, on February 28, 1980 the plant was brought from Mode *3 to Mode 2 with the primary circuit of boron injection tank heat trace *channel 0601A inoperable as indicated by an unsatisfactory surveillance te~t conducted on February 27, 1980.
It was noted that the provisions of the ACTION state-ment were complied with.*
~~l \\ rJ 80041602-%
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- Eldon J. Brunner, Chief 2 -
4-10-80 Reply to Violation
- 1.
The cause was a misinterpretation of Technical Specification 3.5.4.2 Action Statement.
The Action Statement allows operation to continue for up to 30 days with one channel of heat tracing inoperable, provided heat trace temperatures are verified to be!" > 145 °F at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Operating personnel-had identified one heat trace channel as inoperable while conducting*surveillance 4.5.4.2, and in-terpreted "operation may continue" as allowing the mode change from 3 to 2, as long as temperatures were verified to be ~ 145°F at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
- 2.
To correct the situation, a work order was initiated to in-vestigate the inoperable channel and conduct the necessary repair action.
The inoperable channel was subsequently re-paired and the Action Statement was terminated.
- 3.
To prevent future items of noncompliance, (1) surveillance procedure 4.1.2.l(a) will be revised to clarify the re-quirements if a channel is declared inoperable.
(2) A Night Order Book Entry has been made to identify this particular item and specify the interpretation to be utilized in simi-lar situations.
(3) A review of the heat trace system design, operation and instrumentation is in progress with the intent of providing a more reliable, trouble-free system.
If you have any further qu~stions, we will be pleased to discuss them with you.
Sincerely, cc Director, Office of Inspection and Enforcement NRC Washington, DC 20555