ML18094A627

Notice of Violation from Insp on 890527-0710.Violation Noted:Feedwater Isolation Actuation Sys Inoperable During Previous Plant Operations as Result of Inadequate Response Time Testing & Failures to Meet Specified Max Response Time

ML18094A627
Person / Time
Site:	Salem
Issue date:	08/09/1989
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18094A625	List: IR 05000272/1989016 ML18094A627
References
50-272-89-16, 50-311-89-15, EA-89-146, NUDOCS 8908210082
Download: ML18094A627 (32)

Text

APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Salem Nuclear Generating Station Units 1 and 2 Docket Nos. 50-272 50-311 License Nos. DPR-70 DPR-75 EA No.89-146 As a result of the inspection conducted on May 27, 1989 - July 10, 1989, and in accordance with 11General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10 CFR 2, Appendix C (Enforcement Policy 1989), the following violation was identified.

Technical Specifications 3.3.2.l (Unit 1) and 3.3.2 (Unit 2) require, in part, that the feedwater isolation actuation system shall be operable with specified maximum actuation response times.

Technical Specifications 4.3.2.1.3 (Unit 1) and 4.3.2.3 (Unit 2) require that the response times of the feedwater isolation actuation system shall be tested every 18 months and shall include at least one logic train such that both solid state protection system (SSPS) logic trains are tested at least once per 36 months.

Contrary to the above:

1.

On May 26, 1989 for Unit 1 and on May 27, 1989 for Unit 2, the feedwater isolation actuation system was determined to have been inoperable during previous plant operations as a result of inadequate response time testing and the subsequent failures to meet the specified maximum response times when properly tested; and

2.

Prior to May 25, 1989, the feedwater isolation actuation system had not been adequately response time tested in that the testing that was performed did not include feedwater isolation actuation from each of the two SSPS logic trains.

This is a Severity Level IV violation (Supplement 1)

Pursuant to the provision of 10 CFR 2.201, Public Service Electric and Gas Company is hereby required to submit to this office within 30 days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including:

(1) the corrective steps which have been taken and the results achieved: (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.

Where good cause is shown, consideration will be given to extending this response time.

ENCLOSURE 2 ENFORCEMENT CONFERENCE MEETING

SUMMARY

==

I. Introduction:==

On juiy 26, lY8Y, an enforcement conference was held in Region I due to the failure to perform adequate response time testing of the isolation function of the main and bypass feedwater control valves and the subsequent failure of certain of the valves to meet Technical Specification require-ments when properly tested.

The enforcement conference was held to discuss the causes of the event, the licensees corrective actions, and the safety significance of the problem.

In addition, the licensee's philosphy regarding establishing the as-found condition for feedwater control valves and other safety equipment was to be discussed.

II. Meeting Attendees:

NRC S. Collins, Deputy Director, Division of Reactor Projects (DRP)

j. Linville, Chief, Projects Branch No. 2, DRP P. Swetland, Chief, Reactor Projects Section 28, DRP K. Gibson, Senior Resident Inspector S. Pindale, Resident Inspector K. Christopher, Enforcement Specialist, Region I P. Eapen, Chief, Special Test Programs Section, DRS Public Service Electric and Gas Company S. LaBruna, Vice-President, Nuclear Operations L. Miller, General Manager, Salem Operations F. Thomson, Supervisor, Nuclear Licensing D. Strong, Project Manager D. Lyons, Technical Engineer, I&C Systems L. Griffis, I&C System Engineer R. Heaton,.I&C System Engineer G. Raggio, Licensing Engineer J. Musumeci, Operations Engineer,Salem T. Ross, Lead Engineer, Nuclear Fuels Others R. Reichel, Engineer, Delmarva Power Company D. Smith, Staff Engineer, Philadelphia Electric Company M. Cavalier, Engineer, Atlantic Electric Compay

~--~-----~______..:._ __ _

2 III. Meeting Presentation and Discussion:

NRC Region I presented the findings of Inspection Report No. 50-272/89-16; 50-311/89-15 including the details of the apparent violations regarding inadequate time response testing of feedwater isolation, the failure to meet Technical Specification (T.S.) requirements when the test was per-formed properly and the failure to establish the as-found condition for the feedwater control valves.

Unresolved items regarding the discrepancy between the units T.S. valve closure time requirements, and the identifi-cation of cross-wired solenoids were also presented to the licensee for discussion.

The licensee made a presentation on the surveillance testing of feedwater regulating valves.

A copy of the licensee's presentation is included as an attachment to the meeting summary.

The licensee's presentation and subsequent discussion addressed the following:

Licensee engineering assessment of the slow ~RV closure times concluded that no safety significant issue was involved based on the satisfactory results obtained from a design basis analysis of feed-water isolation within 10 seconds and PRA analysis of a complete failure of feedwater to isolate.

With regard to as-found testing, the feedwater isolation valves are the only components identified by the licensee in which the preventive maintenance frequency is the same as the T.S. surveillance frequency.

In general, preventive maintenance intervals are longer than surveil-lance intervals.

Long term corrective actions include a procedure upgrade program to ensure the completeness and technical accuracy of procedures.

==

IV. Conclusions:==

The NRC determined that the failure to adequately test feedwater isolation response times, the slow response times obtained when proper testing was conducted, and hence the inoperability of feedwater isolation during previous plant operations collectively represents a violation of the Technical Specification Limiting Condition for Operation and Surveillance Requirements for feedwater isolation actuation.

The NRC's concerns*

regarding as-found testing have been resolved.

The unresolved items will be addressed in subsequent NRC inspections of the licensee's facility.

\\. **

NRC1 PS~G NRC ENFORCEMENT CONFERENCE SURVEILLANCE TESTING OF FEEDWATER REGULATING VALVES SALEM UNITS 1 & 2 JUL Y 26, 1989 I

I

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PUBLIC SERVICE ELECTRIC AND GAS NRC ENFORCEMENT CONFERENCE FRV SURVEILLANCE TESTING AGENDA INTRODUCTION S. LaBRUNA/L. K. MILLER

- PSE&G UNDERSTANDING OF NRC CONCERN FRV TINE RESPONSE DEFICIENCY

- SAFETY SIGNIFICANCE CROSS NIRING CONCERN AS-FOUND DA TA CONCERN

- FRV SPECIFIC ISSUE

- BROADER IMPLICATION FOR PM PROGRAM TECH SPEC DIFFERENCES FOR FRV RESPONSE TIMES PSE&G ASSESSMENT OF POTENTIAL VIOLATION

- REGULA TORY EVALUATION D. N. LYONS T.K. ROSS D.K. STRONG D.K. STRONG F.X. THOMSON F.X. THOMSON

- APPLICATION OF GENERAL ENFORCEMENT POLICY

SUMMARY

L.K. MILLER NRC2

PSE&G UNDERSTANDING OF NRC CONCERNS NRC FINDINGS e APPARENT VIOLATIONS FAILURE TO INDEPENDENTLY TEST THE FRV AND NSIV RESPONSE TINES FRON BOTH TRAINS OF SSPS ON BOTH UNITS -

TS 4.3.2.J.3 FAILURE OF UNIT J FRVs TO MEET RESPONSE TINE REOUIRENENT -

TS 3. 3. 2. J FAILURE TO ESTABLISH THE AS-FOUND CONDITION PRIOR TO REPLACING FRV SOLENOID VALVES AS REGUIRED BY 0. A. PROGRAM (COMMITS TO ANSI NJB. 7-1976/ANS 3. 2)

UNRESOLVED ITEMS NRC18 INVESTIGATION/EVALUATION OF FRV RESPONSE TINE DIFFERENCES IN TECH SPECS INVESTIGATION/EVALUATION OF VAL VE CROSS WIRING ISSUE ADDRESS BROADER INPLICA TIONS OF NOT TAKING AS-FOUND DA TA OR TESTING UNIT 2 SOLENOIDS PRIOR TO PN REPLACEMENT

FRV TIME RESPONSE DEFICIENCY e

SUMMARY

OF DEFICIENCY SYSTEM/COMPONENT DESCRIPTION AND OPERATION DESCRIPTION OF TESTING METHOD (OLD/NEN)

DISCOVERY METHOD SEOUENCE OF EVENTS ROOT CAUSE ANALYSIS APPLICABILITY TO OTHER PLANT COMPONENTS AND PROCEDURES SHORT TERM CORRECTIVE ACTIONS e LONG TERM CORRECTIVE ACTIONS e

SUMMARY

NRC3

FRV TIME, RESPONSE DEFICIENCY

SUMMARY

OF DEFICIENCY TEST METHOD DID NOT INDEPENDENTLY TEST EACH PROTECTION TRAIN'S ABILITY TO CLOSE THE FRV's FEEDWATER REGULATING VALVE (FRV) FUNCTIONS NRC4 e DURING NORMAL OPERATION, VAL VE MODULA TES TO ADJUST FEEDWATER FLOW TO EACH STEAM GENERA TOR (IN CONJUNCTION WITH MODULATION OF MAIN FEED PUMP SPEED).

e DURING CONDITIONS REOUIRING ISOLATION, VALVE CLOSES TO ISOLATE FEEDWATER FLOW TO THE STEAM GENERATOR e CONTAINMENT ISOLATION (BACKUP TO BF-22)

i FEEDWATER SYSTEM DESCRIPTION OF SYSTEM llaDIO. To Condenaer 22 Chem (BF-19) Feed FW Control Valve BF-22

!!)/0 (Warmup)

.. Feed He1ler1 Cond

.-1-if§Bi-.

(Reclrc)

Conden1er Condensate System

._.... -Mti-ti-From Heater Drain Pumps FEEDWATER ISOLATION SIGNAL

1. TRIPS SG FEED PUMPS

2. SHUTS BF13 VALVES

3. SHUTS BF19 & BF40 VALVES Outside Cont.

1t21 Inside Cont.

FEEDWATER REGULATION VALVE ELECTRO-PNEUMATIC CONTROL From Protection Logic Poailioner Atmosphere

-- Al6 SUpply

• .. *

• Logic Sigr'8I I

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Air Supply COntrol All From Feed Pumps NRC13 (TYPICAL OF FOUR)

NORMAL 0Pi:71ATIDN BOTH SOLENOIDS ENERGIZED PORTS 1 & 2 CONNECTED TO AIR SUPPLY VIA POSITIONER, PORT 3 BLOCKED AIR MAINTAINS FRV OPEN FEEDWA TER ISOLATION ACTUATION BOTH SOLENOIDS DE-ENERGIZED (FAIL SAFE)

PORT J BLOCKEa AIR VENTED TO ATMOSPHERE THROUGH PORTS 2 & 3 FRV CLOSES BY SPRING PRESSURE ToS/G

• NRC5 FRV TIME RESPONSE DEFICIENCY DESCRIPTION OF TESTING METHOD TYPICAL ARRANGEMENT

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125 VDC ATMOSPHERE

¢=:J FEEDNA TER OLD METHOD OPEN 125 voe BREAKER NEASURE FRV CLOSURE TINE NEW METHOD OPEN INDIVIDUAL RELAY CONTACT ASSOCIATED KITH EACH SOLENOID NEASURE FRV CLOSURE TINE

FRV TIME RESPONSE DEFICIENCY DISCOVERY METHOD e SONE PREVIOUS DIFFICOL TY EXPERIENCED IN MEETING REQUIRED RESPONSE TINES e ENGINEERING INVESTIGATION INTO POSSIBLE DESIGN CHANGE OR OTHER ALTERNATIVES TO ADDRESS THE PROBLEM e SYSTEN ENGINEER REVIEWED UNIT J TESTING PROCEDURES LOOKING FOR POSSIBLE INPROVENENTS TO TEST METHODOLOGY e SYSTEN ENGINEER ENHANCED THE UNIT 1 TEST PROCEDURE TO TEST EACH SOLENOID INDEPENDENTL Y NRC6

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NRC7 FRV TIME RESPONSE DEFICIENCY SEQUENCE OF EVENTS e REVISED PROCEDURE HAS REVIEKED AND APPROVED ON NAY 26, 1989 e REVISED TEST PERFORMED ON UNIT 1 LA TE ON MAY 26 WHILE UNIT IN NODE 5; RESULTS ARE ALL VALVES CLOSE 3 OF 16 SOLENOIDS EXCEED TINE RESPONSE LIMIT (INCIDENT REPORT WRITTEN) e EARL Y ON NAY 27, APPLICABILITY OF THE NEH TEST METHOD TO UNIT 2 IS QUESTIONED BY THE OPERA TING DEPARTMENT AFTER REVIEWING ASSOCIATED INCIDENT REPORT e

THE STATION GENERAL MANAGER PRONPTL Y FORMS AND DIRECTS A TEAM OF INDIVIDUALS TO CONPLETEL Y ASSESS IMPLICATIONS TO UNIT 2 e AT 2130 ON NAY 27, DETERNINA TION MADE THAT THE FRV's AND BYPASS VALVES ON UNIT 2 MUST BE DECLARED INOPERABLE.

OPERATIONS BEGINS A CONTROLLED SHUTDOWN.

AT 2147 ON NAY 27, A REPORT IS MADE TO NRC REGION 1

NRCB FRV TIME RESPONSE DEFICIENCY ROOT CAUSE ANALYSIS ROOT CAUSE NASA PROCEDURAL INADEQUACY OLD METHOD OF FRV TESTING DID NOT TEST EACH PROTECTION TRAIN'S ABILITY TO CLOSE FRVs -

BOTH SOLENOIDS OE-ENERGIZED DURING SURVEILLANCE TESTING SIMULTANEOUS OE-ENERGIZING BOTH SOLENOIDS ONLY TESTED "A" VENT PATH ilITH CORRECTED PROCEDURE.

TINE RESPONSE FOR "B" SOLENOID DETERMINED TO BE SLOKER THAN "A" SOLENOID DUE TO DESIGN CHARACTERISTICS TINE RESPONSE USING 118" SOLENOID FOR VENTING AIR OFF THE FRV IS SLOKER BECAUSE THE AIR MUST FLO/i BACKKARDS THROUGH THE "A" SOLENOID FIRST TINE RESPONSE ON 3 OF 8 "B" SOLENOIDS DION IT MEET REQUIRED TINE RESPONSE.

ALL "A" SOLENOIDS HAO ACCEPTABLE TINE RESPONSE

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NRC9 FRV TIME RESPONSE DEFICIENCY APPLICABILITY TD OTHER PLANT COMPONENTS AND PROCEDURES e REVIENED THE TEST METHOD UTILIZED ON ALL PROTECTION SYSTEM COMPONENTS, PRIOR TO EACH UNIT'S RESTART, TO ENSURE INDEPENDENT TRAIN TESTING e ONE ADDITIONAL DISCREPANCY FOUND ON NSIVs BOTH UNITS TEST PROCEDURES REVISED BOTH UNITS NSIVs HERE TESTED PRIOR TO UNIT RESTART ALL MSIVs TESTED SATISFACTORY, PROVING OPERABILITY OF THE VALVES e REVIEN WAS AUDITED BY STATION GA AND ANALYZED IN DEPTH BY NUCLEAR SAFETY REVIEW PRIOR TO UNIT RESTART e CONTACTED 5 OTHER WESTINGHOUSE PNRs NITH SANE SOLENOID CONFIGURATION.

ALL TEST WITH DIFFERENT METHODS.

e NO APPLICABLE INDUSTRY OPERA TING EXPERIENCE EVENTS IDENTIFIED

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FRV TIME RESPONSE DEFICIENCY SHORT TERM CORRECTIVE ACTIONS e REVISED SURVEILLANCE PROCEDURES FOR FRV, FRV BYPASS VALVES, AND NSIV RESPONSE TINE TESTING e REPLACED THE SOLENOIDS llITH AN IMPROVED DESIGN AND MODIFIED TUBING CONNECTIONS ON BOTH UNITS '

FRVs. AND UNIT 2 FRV BYPASS VALVES e SUCCESSFULLY PERFORMED THE REVISED SURVEILLANCE PROCEDURES FOR THE FRVs, FRV BYPASS VALVES AND NSIVs PRIOR TO STARTUP OF BOTH UNITS e REVIEllED A:7SOCIA TED PROCEDURE CHANGES ANO BASIS FOR CHANGES llITH OPERATIONS PERSONNEL e

VERIFIED All OTHER PROTECTION SYSTEM ACTUATIONS INDEPENDENT TRAIN TESTING PROPER RESPONSE TINES e SUBMITTED AN EVENT DESCRIPTION TO NUCLEAR NETllORK FOR DISSEMINATION TO THE INDUSTRY NRC10

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FRV TIME RESPONSE DEFICIENCY LONG TERM ACTIONS e PERFORMING A DETAILED REVIEN OF ALL STATION PROCEDURES TO INCORPORATE APPROPRIATE TECHNICAL AND HUMAN FACTOR IMPROVEMENTS.'?~

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r~\\/~ c.4oJ e -CONTRACTED NESTINGHOUSE TO PERFORM A SAFETY ANALYSIS TO QUANTIFY THE AVAILABLE MARGIN EVALUATE POTENTIAL FOR AN INCREASE IN ALLONABLE TIME RESPONSE TO EXPAND THE OPERA TING BAND e EVALUATING A DESIGN CHANGE TO REDUCE THE TIME RESPONSE ON FRV BYPASS VALVES NRC11

FRV TIME RESPONSE DEFICIENCY

SUMMARY

e ROOT CAUSE HAS -A PROCEDURAL DEFICIENCY e DEFICIENCY WAS SELF-IDENTIFIED INITIATED BY A SYSTEM ENGINEER WORKING TO IMPROVE PLANT SAFETY e ONE SIMILAR TESTING SITUATION WAS IDENTIFIED (MSIVs).

IT HAS SUBSEOUENTL Y CORRECTED.

e PROMPT ACTIONS TAKEN TO BRING THE PLANTS INTO TECH SPEC COMPLIANCE e CORRECTIVE ACTIONS WILL PREVENT RECURRENCE OF SIMILAR EVENTS NRC12

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FRV TIME RESPONSE DEFICIENCY SAFETY SIGNIFICANCE e FRV SAFETY FEATURES FEEDJtlA TER ISOLATION (BACKUP BY SGFP TRIP ANO FJtl ISOLATION VALVES, BF-J3)

BACKUP CONTAINMENT ISOLATION e ENGINEERING ASSESSNENT OF FRV ACTUATION, FEEDJtlA TER ISOLATION JtlITHIN JO SECONDS FAIL SAFE DESIGN SOLENOID VALVES ROUTINELY CHANGED (PRO-ACTIVE PREVENTIVE MAINTENANCE)

EXPERIENCE: NO FRV FAILURE TO ISOLA TE JtlHEN REQUIRED VERIFIED BOTH UNITS FEEDNA TER ISOLATION

< TECH SPEC LIMIT AL THOUGH NOT TESTED INDEPENOENTL Y INDEPENDENT TRAIN B TEST: FEEDNA TER ISOLATION

.8. 6 SECONDS (NORST CASE) e STATISTICAL ANALYSIS OF AVAILABLE VAL VE RESPONSE TINES INDICATES 95% PROBABILITY AT 95%

CONFIDENCE LEVEL THAT THE VALVES NOULD CLOSE IN< JO SECONDS NRC15

FRV TIME RESPONSE DEFICIENCY SAFETY SIGNIFICANCE (CON'T.)

e EVALUATED DESIGN BASIS SAFETY ANALYSIS FOR JO SECOND FEEDJrlA TER ISOLATION -

VERIFI~D ACCEPTABLE RESUL TS FSAR CONCLUSIONS UNCHANGED e PRA STUDY REVEALED THAT THE CONPLETE FAILURE OF FRVs TO ISOLA TE FEEDJrlA TER TO S/G 's ON AN ESF SIGNAL PRODUCES A CHANGE IN CORE DANAGE FREQUENCY (CDF) THAT IS NEGLIGIBLE IN COMPARISON TO THE OVERALL CDF RELATIVE TO All CREDIBLE ACCIDENTS AND FAILURES e NO SIGNIFICANT SAFETY ISSUE

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NRCJ5a

FRV CROSS-WIRING CONCERN

SUMMARY

OF NRC CONCERN e PSE&G SELF-IDENTIFIED AN INSTANCE OF CROSS-lfIRED SOLENOIDS ON ONE FRV.

THIS INOICA TES PREVIOUS IMPROPER RETEST.

PSE&G NEEDS TO EVALUATE ROOT CAUSE ANO IMPACT.

PSE&G RESPONSE e

THE CROSS-KIRING RESUL TEO IN AN INCONSISTENCY KITH OESIGN CONFIGURATION e THE ROOT CAUSE KAS THE INAOEQUA TE FRV TEST PROCEDURE e CORRECTIVE ACTIONS SOLENOID llIRING CORRECTED FRV TEST PROCEDURE REVISED REVIEllEO ALL OTHER SSPS TESTING -

ONE OTHER TEST PROCEDURE llAS REVISED QA PROGRAM KAS REVIEllED ANO FOUND ACCEPTABLE e

NO.ADVERSE SAFETY IMPACT DUE TO CROSS-KIRING.

TRAIN A ANO 8 SOLENOIDS ARE FUNCTIONALLY IDENTICAL NRC2i

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AS-FOUND DATA CONCERN BROAOER IMPLICATION FOR PM PROGRAM NRC CONCERN e DESCRIBE PSEGG PHILOSOPHY TOWARDS ESTABLISHING AS-FOUND CONDITION PRIOR TO PREVENTIVE MAINTENANCE PSE&G RESPONSE ANSI NJB. 7/ANs~s. 2 "TEST ANO INSPECTION PROCEDURES SHALL REQUIRE RECORDING...

AS-FOUND CONDITION, CORRECTIVE ACTIONS PERFORMED, IF ANY.

AND AS-LEFT CONDITION

e PSEGG TEST AND INSPECTION PROCEDURES COMPLY CERTAIN PM TASKS ARE TEST OR INSPECTION PROCEDURES.

i e. CALIBRATION, SURVEILLANCE, DIAGNOSTICS.

AS-FOUND CONDITION JS RECORDED

AS-FOUND DA TA CONCERN BROADER IMPLICATION FOR PM PROGRAM (CONT. -1)

PSEGG RESPONSE (CONT.)

e CERTAIN PM TASKS ARE NOT TEST OR INSPECTION PROCEDURES, ie. OVERHAUL, EO CHANGE-OUT AND COMPONENT REPLACEMENT.

RECORDING AS-FOUND CONDITION IS NOT APPLICABLE SURVEILLANCE TESTING PRIOR TO COMPONENT OVERHAUL OR REPLACEMENT IS MANY TIMES IMPRACTICAL OR NOT PRUDENT COULD RESTRICT OR LIMIT PN PERFORMANCE ON AN UNSCHEDULED OUTAGE COMPONENT OR SYSTEN NAY NOT BE IN A TESTABLE NODE PRIOR TO PN OVERHAUL OR COMPONENT REPLACEMENT NITHOUT PRIOR TESTING CONSISTENT PRACTICE THROUGHOUT PSEGG PN PROGRAM CONSISTENT NITH OTHER UTILITIES CONTACTED

.NRC27A

AS-FOUND DATA CONCERN BROADER IMPLICATION FOR PM PROGRAM (CONT. -2)

PSEGG RESPONSE (CONT.)

BY DESIGN, PM REPLACES OR RENEilS EQUIP1~*fENT PRIOR TO SIGNIFICANT COMPONENT DEGRADATION OR FAILURE PM INTERVALS ARE CONSERVATIVELY ESTABLISHED BASED ON VENDOR RECOMMENDATIONS AND COMPONENT RELIABILITY HISTORY e DUE TO CONSERVATIVE PM SCHEDULE SIGNIFICANT DEGRADATION IS NOT EXPECTED lJ~r~

e MOSvl\\PM COMPONENT REPLACEMENT INTERVALS ARE LONGER THAN SURVEILLANCE INTERVALS e FURTHER, PSE&G IS DEVELOPING A COMPREHENSIVE RELIABILITY CENTERED MAINTENANCE PROCESS e NO ADVERSE IMPACT ON SAFETY e PM PERFORMANCE ilITHOUT PRIOR TESTING FOR AS-FOUND CONDITION IS CONSISTENT i/ITH INDUSTRY PRACTICE NRC278

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AS-FOUND DATA CONCERN FRV SPECIFIC ISSUE NRC CONCERN.

e PSE&G FAILURE TO ESTABLISH AS-FOUND CONDITION FDR FEEDWA TER CONTROL VALVES - IDENTIFY ANY SIMILAR SITUATIONS PSE&G RESPONSE SIGNIFICANCE OF TINE RESPONSE DA TA ON UNIT t DETERMINED - UNIT 2 SHUTDOWN e SORC REVIEWED NEW TEST PROCEDURE.

TESTING OF ALL UNIT 2 FRVs CONSIDERED A PRUDENT MEASURE VERBAL DIRECTION GIVEN FOR INNEDIA TE ACTIONS NO TESTING PERFORMED ON THREE FRVs PRIOR TO CHANGING SOLENOIDS e ROOT CAUSE - INEFFECTIVE CONNUNICA TION e CORRECTIVE ACTION - FORMALIZE METHOD TO CONNUNICA TE IMNEDIA TE ACTIONS FRON SORC IN WRITING AS-FOUND CONDITION WAS NOT REOUIRED NRC28 BUT NOULD *HAVE ASSISTED IN EVALUATING INITIAL PROCEDURAL INADEOUACY

AS-FOUND DA TA CONCERN FR*V SPECIFIC ISSUE (CONT. -1)

PSE&G RESPONSE (CON IT) e SOLENOID VALVE RELIABILITY IS HIGH SOLENOIDS HA VE NOT CAUSED A FAILURE TO ISOLA TE FRVs AT SALEN PSEGG RELIABILITY CENTERED NAINTENANCE EVAL-UATION JUSTIFIES A 7. 5 YR REPLACEMENT INTERVAL 18-NONTH SOLENOID REPLACEMENT INTERVALS ENSURE SOLENOID OPERABILITY THROUGHOUT OPERA TING CYCLE e CHANGING OUT SOLENOIDS NITHOUT TAKING AS-FOUND DA TA HAS NO ADVERSE IMPACT ON SAFETY W~C22b

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TECH SPEC DIFFERENCES-FRV RESPONSE TIMES

SUMMARY

OF NRC CONCERN e PSE&G SHOULD ADDRESS SELF-IDENTIFIED DIFFERENCES IN RESPONSE CLOSURE TIMES BETWEEN UNIT 1 & 2 PSE&G RESPONSE e

TOTAL TIME RESPONSE INCLUDES VAL VE CLOSURE TIME AND SIGNAL LOGIC TIME e

TECH SPECS CLOSURE TIME RESPONSE REGUIREMENTS FOR FRVs:

CONTAINMENT ISOLATION VAL VE TS (VAL VE CLOSURE TINE ONLY)

ENG 'O SAFEGUARD FEA TURES TS (VAL VE Cl OSING G SIGNAL l OGIC) e CLOSURE TIMES REGUIRED BY A CCIOENT ANAL YSJS:

UNIT J UNIT 2 B sec 5 sec 7 sec 7 sec 7 sec 7 sec e CURRENT TECH SPECS BOUND FRV TIMES RE OU IRED BY ANAL YSJS NRC20

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_TECH SPEC DIFFERENCES-FRV RESPONSE TIMES (CONT.)

w VERIFIED TliA T Tl-IE MORE LIMITING ESF TOTAL TIHE RESPONSE REQUIREMENTS (7 SEC) WAS HET FOR ALL PREVIOUS UNIT t FRV CONTAINMENT ISOLATION SURVEILLANCE TESTS (JfITH OLD TEST METHOD) e REVISED UNIT t SURVEILLANCE TEST PROCEDURES TO ASSURE THAT TOTAL.

TIHE RESPONSE IS HET FOR ALL FRV

• CONTAINMENT ISOLATION SURVEILLANCE TESTS e

TECH SPECS If ILL BE UPOA TEO TO ENSURE CONSISTENT TINE RESPONSE REQUIREMENTS e PSE&G KILL IMPLEMENT THE NEN IMPROVED TECH SPECS OEVEL OPED BY ii. 0. 6. /S TRONGL Y ENDORSED BY THE NRC.

JfHICH NILL RESULT IN A COMMON UNIT J/UNIT 2 TECH SPEC NRC21

PSE&G ASSESSMENT OF POTENTIAL VIOLATION REGULA TORY EVALUATION

- e FAILURE TO INOEPENOENTL Y TEST CLOSURE RESPONSE TINE OF THE FRV's ANO NSIV's CONSTITUTES A VIOLATION OF TECH SPEC L CO 3. 3. 2. f e FAILURE TO HEET CLOSURE TIME RESPONSE FOR FRV ALSO RELATES TO LCO 3. 3. 2. f -

SHOULD NOT BE A SEPARATE VIOLA TJON

,\\RC16

PSE&G ASSESSMENT OF POTENTIAL VIOLATION REGULA TORY EVALUATION (CON'T) e FAILURE TO ESTABLISH AS-FOUND CONDITIONS PRIOR TO REPLACING -THE FRV SOLENOIDS SHOULD NOT BE A VIOLATION OF THE PSEGG

0. A. PROGRAM REGUIREMENTS NRC17 ANSI NJB. 7/ANS-3.2 REQUIRES THAT #TEST ANO INSPECTION PROCEDURES SHALL REQUIRE RECORDING AS-FOUND CONDITIONS.

CORRECTIVE ACTIONS PERFORMED, IF ANY, AND THE AS-LEFT CONDITIONS" PSE&G 'S SURVEILLANCE AND TEST PROCEDURES CONPL Y ilITH THESE REOUIRENENTS NO IDENTIFIED REGULA TORY BASIS REQUIRING CONPONENT TESTING PRIOR TO PERFORMING NAINTENANCE/REPLA CEMENT NO ADVERSE IMPACT ON SAFETY PSE&G APPROACH IS CONSISTENT JVITH INDUSTRY PRACTICE-

PSE&G ASSESSMENT OF POTENTIAL VIOLATION APPLICATION OF GENERAL ENFORCEMENT POLICY (tOCFR PART 2, APPENDIX C)

SEVERAL NITIGA TING FACTORS APPLY.*

e DEFICIENCIES WERE SELF-IDENTIFIED BY PSE&G DEMONSTRATES EFFECTIVENESS OF SYSTEM ENGINEER PROGRAM AGGRESSIVE APPROACH TO IDENTIFYING/.

RESOLVING DEFICIENCIES DEFICIENCIES HERE REPORTED IN TIMELY MANNER e COMPREHENSIVE SHORT AND LONG TERM CORRECTIVE ACTIONS HAVE BEEN TAKEN TO *RESOLVE THE DEFICIENCIES AND PRECLUDE RECURRENCE PSE&G HAD NO PRIOR NOTICE OF THE POTENTIAL PROBLEM FRON EITHER PLANT-SPECIFIC EXPER-IENCE OR INDUSTRY/NRC FEEDBACK e DEFICIENCIES ARE NOT SAFETY SIGNIFICANT NRCJ9

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SUMMARY

e A Tl-!OROUG.H FVALUA TION OF THE FRV TINE RESPONSE DEFICIENCY HAS BEEN COMPLETED e ROOT CAUSE HAS BEEN DETERMINED e CORRECTIVE ACTIONS HAVE BEEN TAKEN DEFICIENCY HAS NO SIGNIFICANT SAFETY IMPACT e STUDY PERFORMED TO ENSURE SIMILAR DEFICIEN-CIES DON'T EXIST IN OTHER SAFETY SYSTEMS e PRACTICE OF NOT TESTING COMPONENTS PRIOR TO

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REPLACEMENT IS CONSISTENT NITH REGULATIONS ANO INDUSTRY PRACTICES - NO SAFETY IMPACT e DEFICIENCY NAS SELF-IDENTIFIED AND IS A POSITIVE INDICATION OF PSE&G's INTENTION TO IDENTIFY/CORRECT PROBLEMS e BASED ON SEVERAL NIT/GA TING FACTORS, PSE&G BELIEVES THAT ESCALATED ENFORCEMENT SHOULD NRC25 NOT BE APPLIED TO THIS ISSUE

• • • ~.. -:. :*-.:--*""";".. _