ML18086B419
| ML18086B419 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/02/1982 |
| From: | Uderitz R Public Service Enterprise Group |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML18086B418 | List: |
| References | |
| NUDOCS 8204200288 | |
| Download: ML18086B419 (12) | |
Text
Richard A. Uderitz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 935-6010 Vice President -
Nuclear April 2, 1982 Mr. Ronald c. Haynes, Director Off ice of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pa. 19406 Attention:
Mr. Richard W. Starostecki, Director Division of Resident and Project Inspection Gentlemen:
NRC COMBINED INSPECTION 50-272/82-01 AND 50-311/82-01 SALEM GENERATING STATION UNITS NO. 1 AND 2 JANUARY 1 THEU FEBRUARY 8, 1982 We have reviewed the items of violation which were identified in the inspection conducted between November 24 and December 31, 1981 and described in Appendix A of your letter dated February 2, 1982.
The following are our responses to the identified items:
ITEMS OF VIOLATION Item A Technical Specification 6.8.1 requires the establishment, imple-mentation and maintenance of written procedures as recommended in Appendix "A" of Regulatory Guide 1.33, November 1972, which includes procedures for safety related tagging and expected transients.
Contrary to the above:
- 1.
Administrative Procedure 15, Safety Tagging Program was not followed on January 23, 1982 when the service water and safety injection systems were breached by contractor maintenance personnel without prior verification of system isolation as required by procedure.
(8204200288 82041-5
.I PDR ADOCK 05000272
- G PDR
US.NRG REGION I.
raz ~PR '5 PH I 30
Mr. Ronald C. Haynes, Director 4/2/82 U.S. Nuclear Regulatory Commission
- 2.
As of January 14, 1982, no procedure was in effect cover-ing stuck open secondary safety valves, an expected transient.
Item B Technical Specification 6.11 requires that procedures for radiation protection be prepared and adhered to for all operations involving personnel radiation exposure.
Radiological Protection Program Procedure 24 requires that Radiation Exposure Permits (REPs) be adhered to.
- 1.
Radiation Exposure Permit 0008 required personnel inside the Unit 1 containment bioshield to wear caps and hoods.
Contrary to the above, on January 8, 1982, 3 individuals inside the containment bioshield were not wearing caps and hoods.
- 2.
Radiation Exposure Permit 9901 required personnel inside contaminated areas of the Unit 1 Fuel Handling Building to wear lab coats and gloves.
Contrary to the above, on February 2, 1982, 1 individual inside the contaminated area in the Unit 1 Fuel Handling Building was not wearing a lab coat or gloves.
Item C Technical Specification 6.8.2 states that procedures required by Technical Specification 6.8.1 shall be reviewed by SORC and approved by the Manager prior to implementation.
Contrary to the above, on January 24, 1982, written guidance for reducing power under low feedwater suction pressure conditions, which constituted a procedure for changing load required by Technical Specification 6.8.1 and Regulatory Guide 1~33 had not been reviewed by SORC or approved by the Manager.
Item D Title 10 Code of Federal Regulations Part 50.72 requires prompt (less than one hour) notification be made to the NRC for any event that results in the plant not being in a controlled or expected condition while operating or shut down.
Mr. Ronald C. Haynes, Director U.S. Nuclear Regulatory Commission
- ....3_
4/2/82 Contrary to the above, on January 14, 1982, the plant was operating at 80%.thermal power, 50% turbine power, with the steam dump valves shut, with an abnormally high Tavg, with an unseated steam generator safety valve, and with the rod control system inoperable.
This unexpected condition was not reported to the NRC within one hour.
Reply to Item A (1)
Work Package OP-916140-1307 performed two modifications to the Safety Injection System.
It installed a recirculation line between No. 11 and No. 12 safety injection pumps and installed new flanges for installation of a new flow measuring device.
Work on the safety injection system for addition of' the recircu-lation iines was performed upstream of valve lSJ68.
Work on installation of the flanges was downstream of 1SJ68.
The day Shift Supervisor tagged out the safety injection system upstream of valve 1SJ68 to perform the recirculation line installation.
The day Shift Supervisor was not ready to work on the flanges, so he did not tag out the system downstream of valve 1SJ68.
The package was turned over to the night shift for work.
The night Shift Supervisor assumed that the entire system was tagged out so that he could work on any part of the package.
This was not the case.
The night shift proceeded to cut into the system downstream of valve 1SJ68, which was an active system.
Our investigation of this incident revealed the following:
Th~ work package had a prerequisite section which required a single signature for verification that the affected areas of the system were shut down, drained, tagged, and released for work..
This single signature is confusing in cases where more than one tagout is required to perform work in the same package, such as occurred in this incident.
The requirement for this signature will be deleted from future work packages, and a standard statement will be added to the general notes to cover the tagging warning.
Poor communication between Supervisors contributed to the incident.
The tagging of the system should have been covered in detail during the turnover from days to nights.
The night Shift Supervisor should have personally verified the status of the system prior to cutting into the line.
Mr. Ronald C. Haynes, Director U.S. Nuclear Regulatory Commission 4/2/82 This incident was discusse~ with all supervisors and the importance of proper communications during* turnover was stressed.
Also, the importance of verifying the status of each system prior to working on it rather than taking anything for granted was dis-cussed.
Work Package OP-933432-1307 converted service water to chilled water on No. 1 Energency Air Compressor and Chilled Condenser.
The chilled water piping was tagged out so that demolition could be performed.
Field fabrication on both chilled water and service water piping was in progress.
The marking for the cuts into the service water system had been accomplished.
The pipefitter mechanic misunderstood the direction that was given to him by his Foreman and cut into the operating service water system, which was not tagged out.
The mechanic was directed to cut some fabrication piping for the service water system and cut the previously marked system pipe.
The saw blade broke the surf ace of the piping before the mechanic realized he was cutting the wrong pipe.
The leak was stopped with a rubber patch and clamp.
This incident was attributed to personnel error, and also poor communications between the Foreman and the mechanic.
This incident will be discussed with all Supervisors and Foremen to stress the importance of good communications.
This action will be completed by the contractor Maintenance Superintendent prior to April 2, 1982.
Reply to Item A ( 2)
Regulatory Guide 1.33, Appendix A, does not specifically state that a procedure is required to deal with a stuck secondary safety valve.
However, it does ~tate that procedures are re-quired for expected transients.
An emergency instruction, focused to deal with this type of transient has been developed and approved.
It is expected that the required training will be completed and the emergency instruction formally issued. by April 1, 1982.
At that time we will be in full compliance.
Reply to Item B (1)
REP #0008 was written in the last week of December 1981.
It was to be activated, when needed, after 2400, December 31, 1981.
Mr. Ronald C. Haynes, Director U.S. Nuclear Regulatory Commission 4/2/82 It was written for Unit 1 containment surveillance for the reactor, critical or shut down.
Requiring a hood is standard practice for containment entries when the reactor is critical.
Also, the hood is required for several days after shut down while Xe-133 gas is decaying to a predetermined activity.
When that activity was reached REP #0008 was rewritten for a shutdown reactor.
The hood requirement was taken out and only a cloth cap was required.
When replacing the REP requirement sheets, the Control Point copy which reflected the hood require-ment, was overlooked.
The REP, deleting the hood requirement, was revised and activated at 1300 on January 3, 1982.
Reply to Item B (2)
The individual who was observed in Unit 1 Fuel Handling Building on February 2, 1982 without the proper protective clothing was in violation of EREP 9901.
That individual was a YOH guard.
The sergeant on duty instructed the guards on his shift of the importance of wearing proper PCs in contaminated areas.
Reply to Item C The written guidance that was issued thru an Operations Staff Supervisor was in response to a temporary alarm that was installed on the suction of the steam generator feed pumps to monitor pump suction pressure.
When the memo was issued, it was not realized that the written guidance constituted a procedure and, therefore, it was not reviewed by SORC or approved by the General Manager -
Salem Operations.
Subsequently, the memo was rewritten in an alarm response format and a temporary On-The-Spot Change was initiated to formally issue the document.
The On-The-Spot Change was properly reviewed by SORC and approved by the General Manager -
Salem Operations.
We are now in full compliance.
Reply to Item D The Station Emergency Plan did not indicate that having the unit in an unexpected condition was reportable within one hour to the NRC and was therefore overlooked.
Mr. Ronald C. Haynes, Director U.S. Nuclear Regulatory Commission 4/2/82 Presently, the appropriate sections of the Station Emergency Plan are being revised to include all the requirements of 10CFR 50.72 and upon final approval of the revised documents, distribution will be made to formally issue the new revisions.
The above is expected to be completed by April 1, 1982.
At that time, we will be in full compliance.
An additional item of concern was identified in your transmittal of the above combined inspection items pertaining to secondary plant instability on Salem Unit No. 2 which has caused a number of trips during the first few months of commercial operation.
These trips were related to a loss of feed pump suction pressure and resulted in initiation of an extensive investigation.
This investigation included the instrumentation of condensate, heater drain, and feedwater systems with data collected by high quality tape recorders.
Data retrieval from the tape recorders is correlated into real-time analysis to determine the cause and effect relationship of the systems.
As a result of data acquisition, it was determined that above certain unit loads, a rapid load reduction causes suction pressure at the Steam Generator feed pumps to momentarily decay below the trip set point.
A series of seven load reduction tests was planned and conducted at ~arious power levels to develop an in-depth analysis of the condition.
As a result of this analysis, the attached Operation Alarm Response was prepared and issued to operating personnel advising them of the following:
- 1.
A temporary alarm has been placed in the Control Room.
This alarm alerts operating personnel that feed pump suction pressure is declining to less than 280.0 psig.
- 2.
The low pressure feedwater heater (Nos. 23, 24 and 25) bypass valve should remain open.to reduce differential pressure loss.
- 3.
If an alarm occurs, and a rapid load reduction is required, the condensate polis~er bypass valve can be opened (provided no chemistry problems are present) to recover feed pump suction pressure, thu~ allowing the operators to successfully complete a large load reduction.
Mr. Ronald C. Haynes, Director U.S. Nuclear Regulatory Commission 4/2/82
- 4.
If an alarm occurs and a large load reduction is not necessary, the load shall be reduced in 10% increments until required suction pressure is ~estored for a lower unit load.
Since the implementation of these procedures, there have been no secondary plant instability problems of this nature, which challenge the reactor protection systems.
In an effort to minimize dependence on operator action, we are evaluating future plant modifications.
One principal modifica-tion under consideration involves increasing the condensate pump head by retrofitting new impellers and larger motors.
This will compensate for the reduction of heater drain system flow on load reduction, and the resulting feed pump suction pressure decay.
In addition, we are continuing the use of our monitoring systems in order to retrieve any additional information that may develop.
However, we do feel that we have identified the problem and the steps taken to date wilr insure stable operation at the higher power levels.
The reason for the delay of this submittal was discussed on Wednesday, March 31, 1982 in a telephone conversation between our Mr. E. A. Liden and your Mr. Lowell Tripp.
Concurrence was received from Mr. Tripp to submit this response by April 2, 1982.
cc:
Director, Office of Inspection and Enforcement Nuclear Regulatory Commission Washington, D.C.
20555
21/22 STEAM GENERATOR FEEDWATER PUMPS LOW SUCTION PRESSURE ANNUNCIATOR LOCATION:
Temporarily insta*lled in Control Room.
ORIGIN:
Temporarily installed pressure transmitters on 21122*
Suction Header SET POINT:
300 psig CAUSE:
21/22 SGFP Suction Pressure <300 psig AUTOMATIC ACTION:
None IMMEDIATE ACTION:-
A.
PUMP TRIP*
- -. 1.
If a Feed Pump, Heater Drain* Pump or Condensate Pump has tripped,. reduce-load to the following:
- __ -: :. :'Feed. Pump. -.
<SS% --.
.. _ :'.-... -~*.;* ~.. :._. ~-- -
.. ':.. ~-*
Con~ensate. Pump
<65%
Heater Drain Pump
<85%
2*.
If no serious secondary chemistry problems exist, byp_ass the Condensate Polishing System - Open 21, 22,.
23 CN108.
B.
NO PUMP TRIP
- 1.
Verify 2CN47 is fully open (23, 24, 25 Heater Bypass)
- 2.
If no serious secondary chemistry problems exist, bypass the. Condensat~ Polishing System - Open 21, 22 23 CN108.*
- 3...
If after 21, 22, 23 CN108 are fully open, low suction pressure persists (<300 psig), reduce turbine load by 10% as follows:..
- a.
Reduce turbine reference by 10%.
\\..
- .J-,...
.-,_... -~.:..:.:. ** :... :. ___ :*.:....* '!t~ -*-*.*.* **.
- b.
Set load rate at 200%/min.
- c.
Press GO pushbutton.
- 4.
Allow 30 seconds for the feed system to stabilize.
- 5.
If low suction pressure persists (<300 psig}, continue reducing turbine load in 10% increments until suction pressure is stable or increasing.
Allow 30 seconds between load reductions for the feed system to stabilize.
- .. ~....
STATE OF NEW JERSEY SS.
COUNTY OF ESSEX COUNTY OF ESSES RICHARD A. UDERITZ, being duly sworn according to law deposes and says:
I am a Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in our response dated April 2, 1982, to the NRC's combined inspection report 50-272/82-01 and 50-311/82-01 are true to the best of my knowledge, information and belief.
Subscribed and sworn to before me this 2 Md day of l\\PQ\\\\..
, 1982 N
>* ', M.y
- Commi(:lsion expires on flUDOLPH L von FISCHER JR.
Notary Public of New Jersey
- l\\!lj Comrmss1on EXp1res Sept. 10, 1986
o P-I STATE OF NEW JERSEY
)
).
COUNTY OF ESSEX
)
SS:
COUNTY OF ESSES RICHARD A. UDERITZ, being duly sworn according to law deposes and says:
I am a Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in our responses dated April 2, 1982, to the NRC's combined inspection report 50-272/82-01 and 50-311/82-01 are true to the best of my knowledge, information and belief.
Subscribed and sworn to before me this 2MD day of F'ffQt.*
' 1982 ey RUDOLPH L. von FISCHE.R JR.
Notary Public of New Jer¥Y My GemmissieA Expires Sept. 16, 1 !leB
\\.. My *corrn:nission expires on
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