ML18082A721
| ML18082A721 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 07/02/1980 |
| From: | Schneider F Public Service Enterprise Group |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8007150631 | |
| Download: ML18082A721 (6) | |
Text
-,:--- -,
_:~
Frederick W. Schneider Vice President Pub I ic Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201 /430-7373 Production July 2, 1980 Mr. Boyce H. Grier, Director Office of Inspection and Enforcement USNRC Region 1 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Grier:
NRC INSPECTION REPORT 50-272/80~06 INSPECTION DATES: MARCH 30 -
APRIL 30,1980 SALEM NO. 1 UNIT Pursuant to the subject NRC Inspection Report, we hereby submit the following responses to the identified items of noncompliance and to your concern regarding our implementation of management control systems. This submittal is in accordance with an exten-sion of the response due date to July 7, 1980 by L. Norrholm, NRC Resident Inspector -
Salem, via telephone conversation on June 27, 1980.
Item A, Infraction Technical Specification 6.8.1 states in part: "Written procedures shall be established, implemented and maintained covering *** the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, November 1972". Regulatory Guide 1.33 included Para-graphs A3 Equipment Control (e.g. Locking and Tagging), AB Log Entries and AlO Bypass of Safety Function. The implementing procedure, Operations Directives Manual Revision 5, states, in Section 2.4.5," *** When a new valve lineup is performed, the oper-ator is to position all valves as specified by the valve lineup and initial the appropriate space ****
The completed valve lineup will then be used to record valve deviations resulting from tag-ging or valve manipulations for special plant conditions, the on-duty control operator will note in the 'C&T For or Out of Position Column' the reason *** "
Section 3.1.5 of the Operations Directives Manual states, "Operations Log No. 1 - Control Room Daily Log *.* 2)
/Joo/
s J/1 8007150631
.. ~
~-*-""*':'(...-.
- -* -* H-*----
- -* ~. ------ -*** --
0
- B. 7-2-80 Entries to the narrative portion shall include but not be limited to: **** )Implementation and termination of Technical Specification Action Statements *** " Contrary to the above, on April 11, 1980, manual isolation valve 14AF10 was found to be shut with the locking device locked. This valve is required by operating procedures to be locked open in order to provide auxiliary
_ feedwater flow from the steam-driven auxiliary feedwater pump to #14 Steam Generator. No deviation.in the valve lineup lists was noted, nor any indication provided in the log that the provisions of Technical Specification Action Statement 3.7.1.2 were in effect. No administrative control was identified which would have restored this flow path to operable status within the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> required by the Technical Specifications.
Reply to Item A Our corrective actions in this area have been forwarded to Mr. Boyce H. Grier in a letter dated May 1, 1980. A followup status report was transmitted in our June 5, 1980 letter.
Item B, Infraction Facility Operating License DPR-70 states in paragraph C(l),
"Public Service Electric and Gas*company is authorized to operate the facility at a steady state reactor core power level not in excess of 3338 megawatts (one hundred percent of rated core power)".
Contrary to the above, on April 18, 1980 while operating in steady state, core average nuclear instrument power was recorded in excess of 100% for a period of approximately two and one half hours. Near the end of this interval a calorimetric heat balance indicated nuclear instrument power (average) as 100.6%
and calculated power as 100.24%. An additional one hour period was identified on April 21, 1980 during which steady state oper-
- ation was conducted in excess of 100% as indicated by the aver-age nuclear instrument recorder.
Reply to Item B
- 1.
The nuclear instrumentation system is not a true power level indicator under all core conditions.
During the period of time in question (8:00 a.m. - 11:00 a.m.
on April 18, 1980), a Surveillance Procedure titled "Incore-Excore Calibration" was being performed. A portion of this procedure involves varying the core neutron flux distribution to obtain a range of incore and excore axial offsets. To accomplish the necessary core power distribution changes, control rod motion with accompanying boration and dilution is required
- Power level remains constant with changes in core average temperature (Tavg). These changes in Tavg affect the indica-ted power level from the nuclear instruments (NI's),although the "true" power level, as determined by Delta T's, remains constant. These variations can be shown by examining the actual stripcharts during this time frame. The charts show
B. 7-2-80 that NI indiation increased above 100%, but the Delta T indication did not show a corresponding change. Tavg was above the steam demand during this period resulting in an indicated power level higher than actual power level.
- 2. A calorimetric taken at the completion of this period indicated the.actual power level to be 100.24%. The operator on shift noted the results of the calorimetric and immediately reduced turbine load, as indicated by the associated stripchart. The license does not define "steady state" with regards to time interval. We consider the brief period the reactor core could have been greater than 3338 MWT would not violate the intent of the license.
Item C, Infraction Technical Specification 4.1.3.1.1 requires that the position of each full length rod shall be determined to be within the group demand liinit by verifying the individual rod positions at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> except during time intervals when the Rod Position Deviation Monitor is inoperable, then verify the group positions at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Technical Specification 4.0.2 extends the above interval by 25% to 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
Contrary to the above, during the below listed 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> intervals, no record could be identified to demonstrate that the above determination had been made:
--February 2, 1980 1600 to 2400
--February 3, 1980 0000 to 0800
--February 16, 1980 0000 to 0800
--February 16, 1980 2000 to 0400 (2/17)
--March 8, 1980 1600 to 2400
--April 9, 1980 0800 to 1600
--April 10, 1980 1600 to 2400 Re:elY to Item c
- 1. The Rod Sequence/Deviation Alarm (D-40) has been a continuing problem. This alarm inoperability has added to the normal duties/responsibilities of the control operators and resulted in several missed surveillances identified by the inspector.
- 2. A repair action on the computer program is required to restore the Rod Sequence/Deviation Alarm to an opera~le status. We are in the process of investigating and correcting the alarm problem.
- 3. The restoration of the alarm will eliminate the necessity to perform Technical Specification surveillance 4.1.3.1.1 every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. In addition, the control operators have been emphatically reminded* of the Technical Specification require-ment during conditions of alarm inoperability.
- 4. Date for completion of repairs is July 15, 1980.
B. 7-2-80 Item D, Infraction Title 10 Code of Federal Regulations, Part SO, Appendix B, Criterion XII, Control of Measuring and Test Equipment states:
"Measures shall be established to assure that tools, gages, instru-ments, and other measuring and testing devices used in activities
- affecting quality are properly controlled, calibrated, and ad-justed ~t specified periods to maint~in accuracy within necessary limits~"
Relative to the feedwater flow instruments, which are used in daily calorimetric power calculations and for setting excore nuclear instruments, as required by Technical Specification 4.3.1.1.1, the above requirement is implemented in part by the following licensee procedures; Administrative Procedure 10 (Inspection Order System, Revision 3, dated 10/2/79) and Per-formance Department Procedure PD-1. 4. 005 (Instrument Data Calibration Sheet Instruction, Revision 0). Inspection Order
- 402309, issued under the requirements of Administrative Procedure 10, requires a monthly calibration of Rosemount feed-water flow indicators and Fairchild digital indicators. Instrument Data Calibration Sheet shall be filled in or marked as not applicable.
Contrary to the above, the following determinations were made relative to the feedwater flow instruments and indicators:
- a.
The feedwater flow measuring and indicating devices were over-due for monthly calibration during the period 12 March 1980 through 16 April 1980 while the plant was operating at power.
When calibrated on April 17, 1980 adjustments were necessary to restore the instruments to the required accuracy recorded on the instruments data card.
- b.
No record of calibration of these indicators within one month of return to power operation in December, 1979 was identified.
Calibration was not performed until February 4, 1980, at which time readjustment was required to restore required accuracy.
- c.
No procedural guidance to maintain required accuracy during calibration intervals was identified.
- d.
Information was missing and no applicability specified on the instrument data cards for feedwater flow instruments. This included the following: specification sheet number, inter-connecting W.D. number, functional diagram number, annunciator number, head correction, instrument serial numbers at each calibration.
Reply to* Item D
- 1. Cause a/b. Personnel error. The calibration was missed and the review of the overdue inspection order list failed to identify the required calibration.
__.,._,.,,_, __,;;_ __ "---* - :.~-- ---- ---- - ----- -- -----------~-'"--**-. -
I B. 7-2-80
- c. The station has established a calibration interval of 1 month. The associated vendor's manual specifies a stability guarantee of 6 months. Based on the highly conservative position we *have taken in our calibration interval, we feel the stability between calibrations is assured without additional procedural guidance.
- d. PD-1.4.005 is a draft form procedure and as such has not been approved or implemented.
- 2. Action To Correct a/b. The subject channels have been calibrated satisfactorily.
- c.
N/A
- d.
The instructions stated in PD-1.4.005 will be incorporated into PD-1.4.003 during the next revision.
- 3. Action To Prevent Recurrence a/b. This item is believed to be an isolated case requiring no further action.
- c.
N/A
- d.
The action to correct will prevent recurrence.
- 4. The date for full compliance of Item D is January 1, 1981.
Item E, Deficiency Technical Specification 4.2.4 requires that the Quadrant Power Tilt Ratio shall be determined to be within the limit above 50%
of Rated Thermal Power by calculating the ratio at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during steady state operation when the alarm is inoperable.
Contrary to the above, during the period April 12-13, 1980, while operating above 50% Rated Thermal Power with the deviation alarm inoperable, quadrant power tilt ratios were computed at 1131 on 4/12 and 0346 on 4/13, an interval exceeding 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> plus the 25% allowed by Technical Specification 4.0.2.
Reply to Item E
- 1. Unit 1 was in a power reduction evolution during the identified period of time. Various pump evolutions were in progress (i.e.,
condensate and heater drain pumps were being cycled in and out, Steam Generator Feed Pump Strainers were blown down, etc.) and the operator's attention was devoted to these operations. This attention to other details allowed the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time period to pass without completing the QPTR calculation.
- 2. The operators were counseled on the importance of performing the QPTR calculations.
J
. _............... ~~-.... ~.~- *--*---.. -- ----*--... - -- -.
B. 7-2-80
- 3. The action to correct will prevent recurrence.
- 4. We are in compliance now.
In our F.P. Librizzi to B.H. Grier letter of May 1, 1980 which focused on the concerns of Item A, we listed actions that have been taken to strengthen our management controls. Those steps coupled with the corrective actions taken to address the other items of noncompliance in the subject inspection report should satisfactorily improve the effectiveness of our management controls.
If you have any futher questions, we will be plea~ed to discuss them with you.
Sincerely,
~
(____
CC:
Director, Office of Inspection and Enforcement NRC Washington, DC 20555