ML18096B159
| ML18096B159 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 12/14/1992 |
| From: | Bhatia R, Cheung L, Ruland W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18096B156 | List: |
| References | |
| 50-272-92-16, 50-311-92-16, 50-354-92-17, NUDOCS 9212210322 | |
| Download: ML18096B159 (9) | |
See also: IR 05000272/1992016
Text
I -
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
REPORT/DOCKET NOS.
50-272/92-16
50-311/92-16
50-354/92-17
LICENSE NOS.
LICENSEE:
Public Service Electric & Gas Company
80 Park Plaza - l 7C
Newark, New Jersey
FACILITY:
Salem 1 & 2 and Hope Creek Generating Stations
INSPECTION AT:
Hancocks Bridge, New Jersey
INSPECTION DATES:
October 26-30, 1992
INSPECTORS:
APPROVED BY:
Leonard S. Cheung, Sr. Reacto
Electrical Section, EB, DRS
Ram Bhatia, Reactor Engineer,
Electrical Section EB, DRS
tJ9J.~
W. H. Ruland, Section Chief,
Electrical Section, EB, DRS
'Date
Date
Areas Inspected: Design changes and modifications, the backlog of engineering activities,
dispositioning of nonconformance reports, and corrective actions of previously identified
inspection items were examined.
Results: Design changes and modifications reviewed were of good quality and technically
accurate. Good progress was made in the backlog reduction of engineering work items. A
violation was identified for inadequate corrective actions of a nonconformance report. Two
- previously identified inspection items, for each of Salem units, (50-272/89-13-07,
50-311/89-12-07, 50-272/91-30-01, and 50-311/91-30-01) were updated.
9212210322 921216
ADOCK 05000272
Ci
2
1.0
PURPOSE
The purpose of this inspection was: 1) to determine the quality of the licensee's engineering
activities, such as design changes and plant modification, dispositioning of nonconformance
reports, and reduction of engineering work request backlog; and 2) to review the licensee's
corrective actions of previously identified inspection items.
2.0
TEMPORARY MODIFICATIONS (T-MODS)
The inspector reviewed the licensee's temporary modification program to assure that
temporary installations are performed and controlled by approved procedures.
Procedure NC.NA.AP.ZZ-0013(Q) was established to control temporary modifications at
both Salem and Hope Creek plants. The system engineering group was responsible for the
temporary modifications. For major temporary modifications, both the system engineering
and the corporate engineering group ( E&PB) were involved. A review of the temporary
modification log in the control rooms of all plants revealed that the number of open
temporary modifications were about the same for each unit. Fifty seven (total) temporary
modifications for Salem 1 and 2 compared to twenty seven for Hope Creek. At Salem, the
number of temporary modifications went down to 26, in August 1992. However, at the time
of this inspection the number steadily increased to fifty seven. The steady increase was due
to several systems related leakage problems encountered in secondary small bore pipes of
both Salem units. Several temporary modifications had to be generated to immediately stop
the leaks. The licensee stated that temporary modifications were used frequently between
outages.
The inspector reviewed seven temporary modifications and found them to be of good quality
and according to the established procedure. To resolve the ongoing leakage concern, the
licensee had initiated a five year small pipe revitalization program. The implementation of
this program was scheduled to start during the next refueling outage.
3.0
DESIGN CHANGE AND MODIFICATION PROGRAM IMPLEMENTATION
The inspector reviewed the design change and modification program to assess the quality of
the design change activities. Procedure NC.NA-AP .ZZ-0008, "Control of Design and
Configuration Changes, Tests and Experiments," dated January 16, 1992, was established to
control plant modification packages for the Salem and Hope Creek plants. This procedure
covered design change requests, preparation, review and approval of modification packages,
installation and post-modification testing of the hardware. A Work Book was also established
to supplement the procedure. These documents were reviewed and were found to be
thorough and technically correct. They contained adequate elements to provide proper *
control of the modification packages.
3
The inspectors also reviewed selected design changes and modifications for Salem Units 1 and
2 and Hope Creek to ascertain that they are performed in conformance with the requirements
of Technical Specifications (TS), 10 CPR, the Safety Analysis Report, the licensee's quality
assurance program and procedures. Also, the technical quality of modifications,
thoroughness of design analysis, design input, technical review and safety evaluations,
management involvement and review and resolution of problems from a safety standpoint
were evaluated. The following modifications and simple design changes were reviewed to
assess the licensee's plant modifications.
3 .1
- Replacement of Boric Acid Transfer Pumps - Salem Units 1 and 2
This modification (lEC-30460) replaced the existing Boric Acid Transfer (BAT) Pump shafts
of both units with larger ones. The existing BAT pumps have experienced premature seal
failures for several years. Shortened seal life is attributed to excessive shaft deflection at the
seal faces, increased leakage and seal failures. To reduce the shaft deflection, a new larger
1. 75 inches diameter shaft is planned to replace the existing 1.25 inches diameter shaft for
each of the four BAT pumps at both Salem units.
The inspector's review of this design package identified no concerns. All replacement parts
are supplied by the original equipment manufacturer. The function and operation of the
chemical and volume control system were evaluated by the licensee and determined to be
unaffected by this modification. This was based on the original pump impeller, casing,
piping and pipe connections being retained. The inspector also found the modification
package to be adequately prepared and the station approval for installation to be properly
obtained in accordance with the plant procedures.
3.2
Replacement of Existing Conax Environmental Seals with Namco Quick
Disconnects on Rosemount Transmitters-Hope Creek Unit
This design change (4HC-0320) replaced existing Conax seals with the environmentally
qualified Namco quick disconnects on several Rosemount transmitters that had been
experiencing the loss of silicone fill oil. The Namco disconnects, per design, were
considered to be a direct replacement for the Conax seals.
The inspector noted that this design change package included adequate review of seismic and
environmental qualifications of the newly installed configuration. The safety evaluation and
preoperational test reviewed revealed no concerns. The package was thorough and complete.
The implementation instructions clearly identified the areas where quality assurance approvals
were required .
1 **
4
3.3
Service Water Pipe Replacement for Fan Coil Units- Salem Unit 1
This design change (lEC-3054) replaced the piping of containment fan coil units to*rmyjffive'***
the system integrity and reliability. The inspector's review of the design package revealed that
the licensee had adequately included the applicable design details, safety evaluations, seismic
qualification, pipe stress and support calculations. The package had clearly defined the
hydrostatic and inservice test boundaries. The licensee design review analysis considered the
compatibility of the 6% molybdenum stainless steel alloys for use in service water piping
pressure boundary applications.
The inspector concluded that this package was thorough and complete, and the design change
was accomplished in accordance with the established procedures.
3.4
Additional Design Change Package Review
Four additional modification packages listed below were reviewed:
Mod package 2EC-3104 for the relocation of two cables in Salem Unit 2 hydrogen
monitoring system cabinet 48-2 .
Mod package 2EC-3110 for a trip setpoint change for Salem Unit 2 containment hi-hi
pressure.
Mod packages 2EC-3076 for Salem 2 and lEC-3098 for Salem 1. These two
packages changed the position of the containment cooling fan coil unit service water
supply and return valves from fail-close to fail-open.
These design changes were accomplished in accordance with procedure NC.NA-AP.ZZ-0008
and the Work Book. They contained adequate installation instructions and post-modification
testing information. The safety reviews per 10 CFR 50.59 were technically sound and the
packages were of good quality.
4.0
NONCONFORMANCE CORRECTIVE ACTIONS
Procedure NC.DE-AP.ZZ-0018(Q), "Engineering Discrepancy Control," established a
process to control engineering design nonconformances identified by the engineering
personnel for all units. When a nonconformance is identified, a discrepancy evaluation form
(DEF) is issued by the originator and forwarded to the engineering assessment group (BAG)
for screening, evaluation, resolution and final closing. For plant hardware related
nonconformance conditions, procedure NC.NA-AP.ZZ-0020(Q), "Nonconformance
Program," is used to document the deficiencies. In this case, the plant personnel initiate a
deficiency report (DR) for plant nonconformance. The station technical department is
responsible for resolving the issue and for taking appropriate actions.
5
The inspector selected a sample of ten dispositioned DEFs and DRs for review to determine
whether they had been dispositioned properly. The sample reviewed was found to be
generally acceptable; however, DEF# DES-92-00156, issued on April 15, 1992, for Salem
Unit 1, was inadequately dispositioned. This DEF documented that the fusible link of fire
damper IVHE839 was damaged and the damper had been in the closed position since
March 8, 1991. This deficiency was identified by the licensee on August 29, 1991. The
affected damper is located in fire door Bll-1 of the "C" battery room. During normal
operation, the damper is in the open position to provide a path for makeup air for ventilation.
Proper ventilation is required to assure that the hydrogen concentration is maintained below
the ignition level. The inspector further noted that the DEF had been closed by the licensee
on May 17, 1992, without assuring either: 1) that the safety impact of the deficiency was
properly addressed and the deficiency corrected, or 2) that the nonconformance was
acknowledged by site engineering to followup the issue.
A walkdown by the inspector confirmed that the damper was still in the closed position on
October 29, 1992. The DEF's final disposition recommended that a plant DR should be used
to correct this nonconforming condition. However, there was no evidence that a DR had
ever been generated. In addition, no technical evaluation had been performed by the licensee
to determine the safety impact of this deficiency (i.e., whether the hydrogen concentration
was below the ignition limit). The licensee finally blocked the fire damper open on
October 30, 1992, and provided a fire watch of the inoperable damper until the fusible link
could be replaced. The licensee's lack of prompt corrective actions constitutes a violation of
10 CPR 50, Appendix B, Criterion XVI, which states in part, that: "measure shall be
established to assure that conditions adverse to quality, such as failures,
malfunctions .... defective equipment and nonconformances are promptly identified and
corrected" (50-272/92-16-01).
The Hope Creek DR program identified a problem with minor flaking (pitting) in the
hydraulic control unit (HCU) accumulators. Deficiency Report HMD-92-035 reported that
minor flaking (typical sizes about 1/32" diameter) appeared on the hard chrome plating of the
HCU interior. The flaking was at both ends of the cylinders (accumulators) where the
pistons do not travel. The licensee performed a safety evaluation for this issue. The safety
evaluation indicated that the flaking would not inhibit the movement of the piston during a
reactor scram, and that corrosion of the carbon steel base material would not occur since
demineralized water was used in the control rod drive system and the cylinder interior was
blanketed with a 100% nitrogen environment. The licensee had tried aggressively to gather
more information from other utility companies and vendors to resolve this problem and had
instituted a program to detect similar problems in the remaining HCUs during the refueling
outage .
6
5.0
REDUCTION OF ENGINEERING ACTIVITIES BACKLOG
The backlog of engineering work requests (EWR) was reviewed to assess the licensee's
backlog reduction effort. Review of Hope Creek EWR activities indicated that for each
month in 1992, except April, more EWRs were closed than received. The total EWR
backlog was reduced from 190 at the beginning of this year to 140 in October. Review of
Salem EWR activities indicated similar results. The EWR backlog was reduced from 300 at
the beginning of 1992 to 240 in October. The total number of open EWRs at the
Salem/Hope Creek site, including EWRs common to all three units and administrative type
EWRs, was about 900 at the end of October 1992, compared to 1100 open EWRs at the
beginning of this year.
The licensee stated that they did not have a man-hour estimate for the open EWRs.
Based on the data available, it appeared that the licensee had made substantial progress in
reducing the EWR backlog.
6.0
STATUS OF PREVIOUSLY IDENTIFIED INSPECTION ITEMS
6.1
(Open) Unresolved Item (50-272/91-30-01 and 50-311/91-30-01) pertaining to the
environmental qualification (EQ) of 28 containment-isolation-valve position switches (for each
plant). This issue was identified by the licensee during the July 1991 QA audit and was
documented in a December 1991 NRC inspection report. Following the December
inspection, the licensee issued two internal memoranda, one dated January 3, 1992, the other
dated January 24, 1992. Both memoranda explained why EQ was not required for the
affected valve position switches. The contents of the first memorandum, which the inspector
did not agree with, were discussed in the December 1991 inspection report. The second
memorandum amended the first memorandum and indicated that most of the 28 valves were
located in areas reclassified as a non-harsh environment. From April to June 1992, the
licensee generated 5 engineering evaluations (S-C-SJ-CEE-0670 through -0674) to justify EQ
exemption for the affected valve position switches.
The inspector reviewed all five engineering evaluations and determined that the justifications
presented were reasonable. For most valve position switches, EQ was not required because
they were located in mild environment areas (radiation-harsh only, with total integrated dose
less than 10 4 rads). For those valve position switches not located in mild environment areas,
sufficient engineering bases were provided as to why EQ was not required. These involved
test valves that could be opened only during plant shutdown, and the electrical power supplies
were removed before plant startup. The licensee stated that they would transmit an official
submittal to NRR to request EQ exemption for these valve position switches. This item
remains open pending the licensees submittal of a request for EQ exemption for the valve
position switch .
..
7
6.2
(Qpen) unresolved item (50-272/89-13-07 and 50-311/89-12-07) pertaining to
inadequate cable separations and electrical isolations for various RG 1.97 instrumentation.
These deficiencies were identified by the licensee in 1989 and were documented in the 1989
NRC RG 1.97 inspection report. Following the inspection, the licensee conducted a thorough
walkdown on the RG 1.97 instrumentation. The corrective actions taken by the licensee
included:
a)
In early 1990, the licensee performed an engineering evaluation (S-C-VAR-CEE-0389)
to compare Salem's electrical separation and isolation criteria with RG 1.75 and IEEE
standards. In October 1990, the licensee issued Technical Standards DE-TS-ZZ-1023
and -2032 to be used for a thorough RG 1.97 instrumentation walkdowns.
b)
The walkdown of Unit 1 was conducted during the March 1991 refueling outage.
Many cable-separation and channel-independence deficiencies were identified.
Deficiencies affecting operations were corrected promptly and administrative controls
were implemented until hardware was corrected (e.g., the hydrogen analyzer single
failure problem).
c)
The walkdown of Unit 2 was conducted in the April 1992 refueling outage. Again,
additional cable separation and electrical isolation deficiencies were identified. Design *
change packages were generated to correct these deficiencies.
The inspector considered the corrective actions taken by the licensee to be adequate to close
the original item. However, several items that were identified during the plant walkdown
have not yet been corrected. They are:
1)
Containment isolation valve positions indications for the nitrogen supply lines to the
accumulators. The cable for those indications need to be separated from non-IE
circuitry. This issue is expected to be corrected during the next refueling outage
(Spring I993 for Unit 2 and Fall I993 for Unit I).
2)
Qualifications of the plant computer. This is a large scope project, requiring 2 to 3
years time for completion.
3)
Cable separation issue for low voltage and low energy cables for RG 1.97
instrumentation application.
4)
Four non-class IE breakers used in RG 1.97, Category 1 instrumentation.
5)
RG I.97, Category 1 indicator wiring and non-category 1 wiring from the same power
source. Separation for this wiring is required.
8
6)
Currently no incore neutron monitor recorder was provided. The licensee was
considering either upgrading a non-lE recorder to be connected to a Category 1
instrument loop, or request NRR for an exemption.
The above six items remain unresolved pending further NRC review of licensee's corrective
actions. At the time of the inspection, the licensee did not have the schedule for the
completion of item 2 through item 6.
7.0
EXIT MEETING
At the conclusion of the inspection on October 30, 1992, the inspector met with licensee
representatives denoted in Attachment 1. At that time, the inspector summarized the scope
and findings of the inspection.
.,
ATTACHMENT 1
Persons Contacted
Public Service Electric and Gas Company
- J. Bailey, Nuclear Engineering Science Manager
- A. Blum, Program Analysis Supervisor
- R. Brown, Principal Engineer, License and Regulation
- M. Burnstein, Nuclear Electrical Manager
- J. Carey, Jr., Salem I&C Supervisor
L. Carleto, Project Manager, Salem
- R. Duke, Acting Manager of Projects, Salem
A. Foster, Lead Designer
- W. Gran, Sr. Staff Engineer, Licensing
- M. Gray, Licensing Engineer
B. Hall, Hope Creek, Technical Manager
- D. Jagt, Manager, Nuclear Engineering Designs
W. McDevitt, Sr. Staff Engineer
M. Metcalf, Manager, Special Project
- M. Morroni, Manager, Salem Technical Dept.
- H. Onorato, Licensing Engineer
- C. Sobel, I&C Engineer
- P. Steinhauser, Engineering Assessment Supervisor
- E. Thomson, Manager, Licensing and Regulation
J. Volence, Sr. Staff Engineer
U.S. Nuclear Regulatory Commission
- S. Bar, Resident Inspector, Salem
- K. Lathrop, Resident Inspector, Hope Creek
- S. Pindale, Resident Inspector, Salem
- Denotes those present at the exit meeting on October 30, 1992.