ML18100B045
| ML18100B045 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/26/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18100B044 | List: |
| References | |
| 50-311-94-06, 50-311-94-6, NUDOCS 9405040016 | |
| Download: ML18100B045 (4) | |
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APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Salem Nuclear Generating Station Unit 2 Docket No: 50-311 License No: DPR-75 During an NRC inspection conducted on February 20 - March 26, 1994, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1992), the violation is listed below:
Salem Unit 2 Technical Specification 3.4.5 Action a. requires, in part, that iil modes 1, 2, and 3 with one or more power operated relief valves (PORVs) inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the PORVs to operable status or close the associated block valves and remove power from the block valves; otherwise, be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, on March 25, 1994, at 3:32 a.m., Salem Unit 2 operators closed the PORV block valves making the PORVs inoperable, did not reopen the block valves to restore operability or remove power from the block valves within one hour, and did not put the unit in hot standby within the next six hours.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions 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.
9405040016 940426-PDR ADOCK 05000272 G
NLR-N94095 APPENDIX A NOTICE OF VIOLATION
. Public Service Electr~c-and Gas Company Salem Nuclear Generating Station Unit 2 Docket No: 50-311 License No: DPR-75 During an NRC inspection conducted on February 20 - March 26, 1994, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix c (1992),
the violation is listed below:
Salem Unit 2 Technical Specification 3.4.5 Action a. requires, in part, that in modes 1, 2, and 3 with one or more power operated relief. valves (PORVs) inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the PORVs to operable status or close the associated block valves and remove power from the block valves; otherwise, be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above,. on March 25, 1994, at 3:32 a.m., Salem Unit 2 operators closed the PORV block valves making the PORVs inoperable, did not reopen the block valves to restore operability or remove power from the block valves within one hour, and did not put the unit in hot standby within the next six hours.
This is a Severity Level IV violation (Supplement I).
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- NLR-N94095 ATTACHMENT I PSE&G RESPONSE PSE&G does not dispute the violation.
The root cause of this violation has been attributed to inadequate procedural guidance.
On March 25, 1994, Salem 1 operating personnel were in the process of identifying the source of Reactor Coolant System (RCS) inleakage to the Pressurizer Relief Tank (PRT).
Both Power Operated Relief Valve (PORV) block valves were closed in accordance with Abnormal Operating Procedure (AOP)
S2.0P-AB.PZR-0001 (Q), Pressurizer Pressure Malfunction.
Although the procedure directed the operators to close both block valves, it did not alert the operators to enter Technical Specification (T/S) 3.4.5 following completion of the action.
It was not until review of the procedure technical basis that it was determined that the T/S applied.
Operating shift personnel were cognizant of T/S 3.4.5 requirements, and its associated T/S Interpretation (2-LC0-3.4.5).
Neither document clearly required that_ the PORVs be considered inoperable with their associated block valves closed.
Operating personnel also did not consider the PORVs inoperable since they were following AOP procedural requirements, and the block valve could be opened if needed.. An operator was stationed at the valve controls to open the valve, if required.
The PORVs are designed to minimize challanges to the Pre~urizer safety relief valves.
However, no credit is taken for automatic operation of these valves during Design Basis Accidents.
PSE&G would like to clarify an apparent misunderstanding as it relates to management expectations regarding Technical Specifications compliance.
Specifically as stated on page 2 of Inspection Report 50-272/94-06, and 50-311/94-06;
" *.* Operations management concluded that it was reasonable to permit the control room operators to complete troubleshooting since they had already failed to meet the regulatory requirement".
PSE&G management does not condone any course of action other than compliance with requirements of Technical Specifications.
Once it has been identified and determined that a condition exists, which violates Technical Specification requirements, the action statement is to be entered immediately regardless of the amount of time that the non compliance has existed.
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- CORRECTIVE STEPS TAKEN AND CORRECTIVE STEPS TAKEN TO PREVENT AVOID FUTURE VIOIATIONS Operations Department management:
- i. Reviewed this event with involved Operations personnel.
- 2. Informed all operators, via entries in the Night Order Book on March 25, 1994 and re-enforced on M~rch 31, 1994, of the requirement to enter T/S 3.4.5 whenever the PORV block valve(s) are closed.
- 3. Will review the need to.modify T/S Interpretation 2-LC0-3.4.5, during implementation of License Amendment Nos 150 and 130.
This amendment allows closure of the PORV block valves without having to remove power from the block valves.
- 4. Will modify Abnormal Operating Procedure (AOP)
S2.0P-AB.PZR-0001 to ensure appropriate Technical Specification references are included whenever the PORV block valve(s) are closed.
This event will be reviewed for lessons learned in licensed operator requalification training.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED PSE&G believes that adequate controls are in place to ensure continued operability of the Power Operated Relief Valves.
PSE&G
- is in full compliance.